Justia Massachusetts Supreme Court Opinion SummariesArticles Posted in Products Liability
Doucet v. FCA US LLC
The Supreme Judicial Court vacated the judgment of the trial court dismissing FCA US LLC from the underlying tort lawsuit, holding that Massachusetts had personal jurisdiction over FCA US under the Commonwealth's long-arm statute, Mass. Gen. Laws ch. 223A, 3, and the due process clause of the Fourteenth Amendment.Paul Doucet was the passenger in a car that was involved in an accident in New Hampshire, rendering him incapacitated. Doucet's guardians filed suit against FCA US, the vehicle's manufacturer, and the Massachusetts distributor-dealership Sudbay Chrysler Dodge, Inc. FCA US, a Delaware limited liability company with its principal place of business in Michigan, filed a motion to dismiss for want of personal jurisdiction. The trial judge granted the motion and dismissed FCA US as a party to the case, concluding that Massachusetts lacked personal jurisdiction under both the long-arm statute and the due process clause of the United States Constitution. The Supreme Judicial Court vacated the judgment below, holding that personal jurisdiction existed in Massachusetts over FCA US for the underlying claims pursuant to both the Commonwealth's long-arm statute and the Fourteenth Amendment's due process clause. View "Doucet v. FCA US LLC" on Justia Law
Nemirovsky v. Daikin North America, LLC
The Supreme Judicial Court affirmed the superior court judge's directed verdict in favor of DACA Delaware Dissolution Trust (DACA Trust) and Stebbins Duffy, a manufacturer's representative of Daikin Industries' products, on Ofer Nemirovsky's claims for breach of the implied warranty of merchantability and vacated the judgment entered against Daikin North America, LLC (Daikin NA), holding that the court erred in part.The trial judge declined to apply the "component parts doctrine" to the nondefective component distributed by Daikin NA because the component was not itself a "standalone" product and was designed specifically for use in the integrated product. The judge then granted directed verdict for Defendants on Nemirovsky's claims for breach of the implied warranty of merchantability against the original sellers of the HVAC system. The Supreme Judicial Court (1) vacated the judgment entered against Daikin NA, holding that the component parts doctrine precluded liability; and (2) affirmed the judge's directed verdict for Defendants on Nemirovsky's claims for breach of the implied warranty of merchantability against the original sellers of the HVAC system, holding that the claims were time barred. View "Nemirovsky v. Daikin North America, LLC" on Justia Law
Dunn v. Genzyme Corp.
In this case involving claims of personal injury and product liability against the manufacturer of a medical device the Supreme Judicial Court reversed the decision of the superior court judge denying the manufacturer's motion to dismiss, holding that plaintiffs asserting parallel state law claims may do so with no greater degree of specificity than otherwise required under Iannacchino v. Ford Motor Co., 451 Mass. 623, 636 (2008).Plaintiff sued Genzyme Corporation, asserting that Synvisc-One, a class III medical device subject to premarket approval under the Medical Device Amendments (MDA), 21 U.S.C. 360c et seq., was negligently manufactured, designed, distributed, and sold by Genzyme. Genzyme filed a motion to dismiss on the grounds that the allegations were preempted by federal regulation. The trial judge denied the motion to dismiss. The Supreme Judicial Court reversed, holding that while all of Plaintiff's state law claims properly paralleled the federal requirements, none of them was sufficiently pleaded under Iannacchino to survive Genzyme's motion to dismiss. View "Dunn v. Genzyme Corp." on Justia Law
Am Int’l Ins. Co. v. Robert Seuffer GmbH & Co. KG
Plaintiff-insurance company filed suit against Defendant-manufacturer, alleging various theories of products liability. Defendant raised the defense of a lack of personal jurisdiction in its answer but did not file a motion to dismiss the case on that basis. Twelve months after filing its answer to the complaint, during which time Defendant pursued litigation on the merits, Defendant filed a motion for summary judgment based on the defense of a lack of personal jurisdiction. The superior court denied Defendant’s motion, concluding (1) the court lacked personal jurisdiction over Defendant, but Defendant waived this defense by litigating the merits of the case and thereby submitting to the jurisdiction of the court; and (2) genuine issues of material fact existed as to the merits, which precluded the entry of summary judgment. The Supreme Judicial Court affirmed, holding (1) where a party raises the defense of lack of personal jurisdiction in a responsive pleading, the party’s subsequent conduct may, in some circumstances, result in a forfeiture of that defense; and (2) the superior court did not err in denying Defendant’s motion for summary judgment in this case.View "Am Int’l Ins. Co. v. Robert Seuffer GmbH & Co. KG" on Justia Law
Aleo v. SLB Toys USA, Inc.
In 2006, while visiting relatives in Andover, 29-year-old Aleo attempted to use an inflatable swimming pool slide that had been imported and sold by Toys R Us. She slid down head first; when she reached the bottom of the slide, it collapsed, and her head struck the concrete deck of the swimming pool through the fabric of the slide. Robin's upper two cervical vertebrae fractured, resulting in quadriplegia. She died the following day, after her family, in accordance with her wishes, withdrew life support. Her estate sued, alleging negligence, breach of the implied warranty of merchantability, wrongful death, and violation of G.L. c. 93A. A jury found Toys R Us liable for negligence, breach of warranty, and wrongful death, awarding compensatory damages of $2,640,000 and punitive damages of $18 million. Under G.L. c. 229, punitive damages available for gross negligence in wrongful death action. The Massachusetts Supreme Court affirmed, finding that Toys R Us exhibited a “substantial degree of reprehensibility.” The court rejected challenges to pretrial rulings, the sufficiency of the evidence, and the constitutionality of the $18 million award of punitive damages. View "Aleo v. SLB Toys USA, Inc." on Justia Law