Justia Products Liability Opinion Summaries

The Supreme Court held that, at least where specific jurisdiction is asserted, Tex. R. Civ. P. 120a discovery need not relate exclusively to jurisdictional issues without touching on merits issues.The parties in this suit concerning water leaks from plastic pipe made of cross linked polyethylene failed to agree on the scope of two corporate representative depositions, and so the trial court granted a motion to compel the depositions on a list of thirty topics proposed by Plaintiffs. The nonresident defendant sought mandamus relief, which the court of appeals granted, concluding that the trial court erred in compelling discovery on topics that touched both jurisdictional and merits issues. The Supreme Court directed the court of appeals to vacate its mandamus order, holding (1) the trial court did not abuse its discretion merely by compelling discovery on jurisdictional topics; (2) the standard for trial courts to apply is that the information sought must be essential to prove at least one part of the plaintiff's theory of personal jurisdiction; and (3) general principles that limit the scope of discovery apply equally to jurisdictional discovery. View "In re Christianson Air Conditioning & Plumbing, LLC" on Justia Law

The Supreme Court answered in the negative a question posed by the United States Court of Appeals for the Fifth Circuit regarding whether Amazon.com is a "seller" under Texas law when it does not hold title to third-party products sold on its website but controls the process of transaction and delivery, holding that Amazon is not a "seller" of third-party products under Texas law.At issue was whether third-party e-commerce platforms such as Amazon, eBay, Etsy, and Alibaba are strictly liable for defective products manufactured and owned by third parties. The Supreme Court answered the question in the negative, holding (1) under the Legislature's definition of "seller" in Chapter 82 of the Civil Practice and Remedies Code, when the ultimate consumer obtains a defective product through an ordinary sale, the potentially liable sellers are limited to those who relinquished title to the product at some point in the distribution chain; and (2) because the product in this case was sold on Amazon's website by a third party and Amazon did not hold or relinquish title, Amazon was not a seller even though it controlled the process of the transaction and the delivery of the product. View "Amazon.com v. McMillan" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's denial of SprayFoamPolymers.com LLC's special appearance contesting personal jurisdiction, holding that the court of appeals erred in dismissing SprayFoam from Plaintiffs' suit for lack of jurisdiction.Plaintiffs built a home in Texas, purchased spray foam insulation services from a Texas-based installation company, and suffered injuries in Texas allegedly arising from the insulation. Plaintiffs sued several defendants, parties in the chain of distribution, seeking to hold them liable for their alleged injuries. SprayFoam, the manufacturer of the insulation, filed a special appearance contesting personal jurisdiction. The trial court denied the special appearance. The court of appeals reversed, concluding that Plaintiffs failed to establish either general or specific personal jurisdiction over SprayFoam. The Supreme Court affirmed, holding that SprayFoam had sufficient minimum contact with Texas such that the exercise of specific jurisdiction over SprayFoam will not offend traditional notions of fair play and substantial justice. View "Luciano v. SprayFoamPolymers.com, LLC" on Justia Law

In this products liability action, the Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the trial court against Petitioners, holding that legally sufficient evidence supported the jury's design-defect findings and that the trial court's jury instructions did not cause an improper verdict.An electric terminal manufacturer made two terminals for essentially the same cost, but the older of the two designs was more susceptible to failure. A corporate affiliate of the terminal maker decided to use the older product in manufacturing new air conditioning compressors. When an experienced HVAC technician purchased and installed a compressor containing the older terminal design, the compressor became overheated and the terminal emitted scalding pressurized fluids that ignited and covered the technician. The technician, who received serious burns, brought this action. The jury found that the older terminal design was unreasonably dangerous and that both the design and the failure warn caused the technician's injuries. The court rendered judgment on the jury's verdict. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "Emerson Electric Co. v. Johnson" on Justia Law