Justia Injury Law Opinion Summaries

Matthew Cartia and Autumn Adams were arrested by officers when they attempted to interfere with a police investigation at Cartia's parents' house. The officers claimed that Cartia and Adams were interfering with their work, leading to a confrontation where Cartia was handcuffed and taken down using a "hip-toss" maneuver. Adams was also arrested after she tried to intervene. Both Cartia and Adams alleged that the officers used excessive force during and after their arrests, including claims that Cartia was struck and choked by the officers.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the defendants, including the officers and Lincoln County. The magistrate judge concluded that the officers were entitled to qualified immunity and that Lincoln County was not liable under Monell for the officers' actions.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the grant of summary judgment for some claims but reversed it for others. The court held that the officers were entitled to qualified immunity for most of their actions, including the initial takedown and restraint of Cartia, as well as the force used against Adams. However, the court found that there were genuine issues of material fact regarding the excessive force claims against Officers Beeman and Gugliano for allegedly striking and choking Cartia after he was subdued. These claims were remanded for further proceedings. The court also found that the state law claims of assault and battery and negligence against these officers should proceed to trial, as there was sufficient evidence to suggest they may have acted with malice or bad faith. The court affirmed the dismissal of the remaining claims. View "Cartia v. Beeman" on Justia Law

Following heavy snowfall in Pine Bluff, Arkansas, the roofs of several chicken houses at ten poultry farms collapsed. Norfolk & Dedham Mutual Fire Insurance Company, which insured the farms, sued Rogers Manufacturing Corporation, the manufacturer of the roof trusses used in the chicken houses, claiming strict product liability, negligence, and breach of warranties. Rogers moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6), arguing that Norfolk’s claims were barred by the Arkansas statute of repose.The United States District Court for the Eastern District of Arkansas agreed with Rogers and dismissed the complaint. Norfolk appealed the dismissal, arguing that the statute of repose did not apply to Rogers because the roof trusses were standardized goods, not custom-designed for the farms.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo, accepting the allegations in the complaint as true and drawing all reasonable inferences in Norfolk’s favor. The court found that Norfolk’s complaint plausibly supported an inference that the roof trusses were standardized goods, which would not be covered by the Arkansas statute of repose. The court emphasized that at this early stage, the complaint should not be dismissed if it allows for a reasonable inference of liability.The Eighth Circuit reversed the district court’s dismissal of the complaint and remanded the case for further proceedings, noting that the facts and legal arguments could be further developed as the case progresses. View "Norfolk & Dedham Mutual Fire Insurance Company v. Rogers Manufacturing Corporation" on Justia Law

Sisters Nikki Mazzocchio and Angela Kraus filed a federal "public liability action" under the Price-Anderson Act (PAA) against several defendants, alleging that exposure to radioactive waste caused them to develop cancer. The waste had been handled by various entities over the years, including Mallinckrodt, Cotter Corporation, and Commonwealth Edison Company. The plaintiffs claimed negligence, negligence per se, strict liability, and civil conspiracy. The defendants moved to dismiss the complaint, arguing that federal law preempted the state-law claims because federal nuclear dosage regulations provide the exclusive standard of care in a public liability action. The district court denied the motions to dismiss, and the defendants appealed.The United States District Court for the Eastern District of Missouri denied the defendants' motions to dismiss, holding that the plaintiffs' state-law claims were not preempted by federal law. The court found that the plaintiffs had adequately pleaded their case under state tort law standards. The defendants then sought and were granted permission to appeal the decision.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court held that state tort law standards of care are not preempted by federal nuclear dosage regulations in a public liability action under the PAA. The court referenced the Supreme Court's decision in Silkwood v. Kerr-McGee Corp., which established that state tort law applies in cases involving nuclear incidents, despite the federal government's exclusive control over nuclear safety regulation. The court also noted that Congress, through the PAA's 1988 amendments, did not repudiate the role of state tort law in such cases. Therefore, the Eighth Circuit concluded that the district court correctly denied the defendants' motion to dismiss, allowing the plaintiffs' state-law claims to proceed. View "Mazzocchio v. Cotter Corporation" on Justia Law

Ryan Davis and Anthony Crane ordered wet ready-mix concrete from Simon Contractors for a garage floor project. Both had limited experience with concrete, though Davis had experience with a similar product called thinset. The concrete was delivered in two truckloads, and Davis and Crane worked without proper protective equipment. They suffered severe chemical burns from prolonged contact with the wet concrete.The United States District Court for the District of Nebraska held a jury trial. Davis and Crane claimed Simon Contractors was negligent for failing to warn about the dangers of wet concrete. The jury found in favor of Simon Contractors. Davis and Crane appealed, arguing errors in jury instructions and the admission of evidence about Davis’s prior litigation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court correctly instructed the jury on the sophisticated user and assumption of risk defenses under Nebraska law. The court held that Davis and Crane’s experience with similar products and the warnings provided were sufficient for the jury to conclude they knew or should have known the risks. The court also found no error in the assumption of risk instruction, as evidence showed Davis and Crane were aware of the dangers and failed to take necessary precautions.Regarding the cross-examination about Davis’s prior litigation, the court ruled that any error in admitting this evidence was harmless. The probative questions were about Davis and Crane’s knowledge of the risks, and the evidence on these issues was clear. The court affirmed the district court’s judgment in favor of Simon Contractors. View "Davis v. Simon Contractors, Inc." on Justia Law

David Burke died after falling down retractable steps attached to his motorhome. His estate, wife, and children filed product liability claims against Lippert Components, Inc., and LCI Industries, who had purchased the product brand after the Burkes bought the vehicle. The plaintiffs alleged negligence, design defects, manufacturing defects, and inadequate instructions and warnings. They later sought to add the previous owners of the product brand as defendants and amend the scheduling order, but the district court denied these motions and granted summary judgment in favor of Lippert and LCI.The United States District Court for the Northern District of Iowa denied the plaintiffs' motions to amend the complaint and the scheduling order, citing unreasonable delay. The court then granted summary judgment for Lippert and LCI, finding that they did not manufacture, distribute, or sell the steps in question, and thus were not liable under Iowa law. The plaintiffs appealed these decisions.The United States Court of Appeals for the Eighth Circuit affirmed the district court's rulings. The appellate court held that Lippert and LCI were not required to plead an affirmative defense regarding successor liability, as their defense negated an essential element of the plaintiffs' claims. The court also found that Lippert and LCI did not assume liability through the purchase agreement and that expert testimony was necessary to support the claim of inadequate post-sale warnings. Finally, the court agreed that the plaintiffs failed to show good cause for their delayed motions to amend the complaint and scheduling order. The judgment of the district court was affirmed. View "Burke v. Lippert Components, Inc." on Justia Law

Teddy and Melanie Scott filed a lawsuit against Dyno Nobel, Inc., alleging that Teddy suffered serious injuries from exposure to a toxic gas cloud negligently emitted from Dyno’s nitric acid plant in Louisiana, Missouri. The incident occurred on March 20, 2015, when an equipment failure during a startup led to the release of nitrogen oxide gas, which enveloped Teddy while he was working at a nearby plant. Teddy experienced immediate physical symptoms and has since suffered from ongoing health issues, including irritable larynx syndrome, headaches, and back pain. Melanie claimed loss of consortium due to Teddy’s injuries.The United States District Court for the Eastern District of Missouri initially granted summary judgment in favor of Dyno, concluding that Dyno owed no duty of care to Teddy. However, the United States Court of Appeals for the Eighth Circuit reversed this decision, finding that the issue of foreseeability, which determines duty, should be decided by a jury. On remand, a jury trial resulted in a verdict for the Scotts, awarding Teddy $13,750,000 in compensatory damages and $30 million in punitive damages, and Melanie $3 million in compensatory damages. Dyno’s post-trial motions for judgment as a matter of law or a new trial were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment in part. The appellate court found that the jury had sufficient evidence to determine that Dyno’s actions created a foreseeable risk of harm and that Dyno breached its duty of care. However, the court reversed the award of punitive damages, concluding that the Scotts did not provide clear and convincing evidence that Dyno acted with a culpable mental state necessary for punitive damages under Missouri law. The case was remanded for entry of an amended judgment omitting the punitive damages award. View "Scott v. Dyno Nobel, Inc." on Justia Law

Ricky Hughes, a railroad employee, was injured twice at work during his Chapter 13 bankruptcy proceedings. He did not disclose these potential personal injury lawsuits to the bankruptcy court. About 19 months after his bankruptcy closed, Hughes filed a personal injury lawsuit against his employer and other defendants. The district court granted summary judgment against Hughes based on standing and judicial estoppel, as he had not disclosed the potential lawsuit in his bankruptcy.The United States Court of Appeals for the Eighth Circuit found that Hughes had standing to bring the lawsuit. The court reasoned that the claims vested with Hughes, as per Section 1327 of the Bankruptcy Code, which provides that estate assets vest with the debtor. The court rejected the defendants' argument that Section 554(d), which provides that undisclosed estate assets that have not been expressly abandoned remain property of the estate, should control.The court also applied the doctrine of judicial estoppel, which prevents a party from asserting a position in a case that is clearly inconsistent with a position it took in a previous case. The court found that judicial estoppel applied to claims arising from the first incident but not the second. The court reasoned that when Hughes was injured for the second time, he had already made all of the payments required under his five-year plan, and there was no permissible statutory basis to modify the plan. Therefore, the bankruptcy court did not rely on the second nondisclosure, and there was no risk of inconsistent court determinations or threats to judicial integrity. The court affirmed in part, reversed in part, and remanded the case for further proceedings. View "Hughes v. Wisconsin Central, Ltd." on Justia Law

In October 2018, Molitor Equipment, LLC purchased two tractors from Deere & Company. These tractors were a transitional model and did not include engine compartment fire shields as standard equipment, which were included in the subsequent 2019 model. A year after purchase, both tractors caught fire in separate incidents. Molitor had an insurance policy with SECURA Insurance Company, who paid Molitor's claim and then pursued Molitor's warranty claims against Deere. SECURA claimed the tractors were defective and unreasonably dangerous due to the absence of the fire shields and that Deere's warranty obligated them to remedy the problem or refund the purchase prices.Deere moved to dismiss the claims, arguing that its warranty only covered manufacturing defects, not design defects. The district court granted Deere's motion, dismissing SECURA's breach of warranty claim to the extent it was based on a design defect theory. The case proceeded on a manufacturing defect theory. At the close of discovery, both parties moved for summary judgment. Deere argued that since the tractors conformed to their intended design, there was no manufacturing defect. The district court granted Deere's motion, holding that SECURA could not establish its breach of warranty claim because Deere's warranty covers defects only in "materials or workmanship."On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decisions. The appellate court agreed with the district court's interpretation of Deere's warranty, concluding that it did not cover design defects. The court also agreed that SECURA could not establish a breach of warranty claim based on a manufacturing defect, as the tractors conformed to their intended design. Therefore, the court affirmed the district court's dismissal of SECURA's design defect claim and its grant of summary judgment to Deere on the manufacturing defect claim. View "Secura Insurance Company v. Deere & Company" on Justia Law

In 2021, a warehouse developed by TriStar Companies, LLC but possessed by Amazon collapsed during a tornado, causing injuries and deaths. Several personal injury and wrongful death lawsuits were filed against TriStar, claiming negligence in the warehouse's construction. TriStar, insured by AXIS Surplus Insurance Company, sought coverage under their policy, but AXIS denied coverage and filed a complaint for a declaratory judgment that it had no duty to defend or indemnify TriStar for the resulting lawsuits. The district court granted AXIS's motion for summary judgment, ruling that the insurance policy did not cover the warehouse due to certain exclusions and limitations.Upon appeal, the United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision. The Court of Appeals applied Missouri law, giving the insurance policy terms "the meaning which would be attached by an ordinary person of average understanding if purchasing insurance." The court found that the policy's language was clear and unambiguous. It limited coverage to premises owned, rented, or occupied by TriStar per a schedule of locations on file with AXIS. As the warehouse's location was not listed in the schedule, and TriStar did not own, rent, or occupy the warehouse when the incident occurred, the court concluded that the policy did not cover the incident.The court rejected TriStar's interpretation of the schedule of locations, which would have resulted in coverage extending to an entire city, as untenable and against common sense. Therefore, AXIS had no duty to defend or indemnify TriStar for the lawsuits arising from the warehouse collapse. View "Axis Surplus Insurance Company v. TriStar Companies, LLC" on Justia Law

Cynthia Bowen purchased an insurance policy from Farm Bureau Property & Casualty Insurance Company ("Farm Bureau") for her pick-up truck. She was injured when an employee of Menard, Inc. ("Menards") accidentally dropped a large board on her while helping load her truck at a store. Bowen sued Menards for damages, alleging negligence. Menards then filed an action against Farm Bureau seeking a declaratory judgment that it was entitled to a defense and indemnification from Farm Bureau under Bowen's insurance policy. The district court ruled in favor of Menards, finding that Menards and its employee were covered insureds under the policy and that no policy exclusion applied.On appeal, the United States Court of Appeals for the Eighth Circuit reversed the district court's decision. The court concluded that the policy's "Intrafamily Immunity" exclusion applied to the case. This exclusion stated that there was no coverage for any bodily injury to any "insured," which, in this case, included both Bowen and Menards. Therefore, the policy provided no liability coverage for Bowen's claim against Menards, another insured party. The court rejected the district court's reasoning that the term "intrafamily" limited the application of the exclusion, finding that the plain meaning of the operative policy provision prevailed. The court also rejected Menards' argument that Farm Bureau was estopped from asserting this defense to coverage. Consequently, the court reversed the district court's judgment, ruling that Farm Bureau was not obligated to provide defense and indemnification for Menards in connection with the lawsuit brought by Bowen. View "Menard, Inc. v. Farm Bureau P&C Ins. Co." on Justia Law