Justia Injury Law Opinion Summaries

A tenant and her adult son rented a house in Arlington, Virginia, for a year. Several months into the lease, they noticed water leaking through a skylight and informed the landlord. The landlord and a contractor inspected the skylight and confirmed it was leaking, but no repairs were made. After a period of snow and rain, the tenant slipped on water that had accumulated from the leak, suffering significant injuries. She then sued the landlord, alleging breach of contract for failing to complete repairs as required by the lease and state law, and common-law negligence in failing to take steps to prevent injury from the leak.The landlord removed the case to the United States District Court for the Eastern District of Virginia, which treated the landlord’s demurrer as a motion to dismiss. The district court dismissed the negligence claim, finding the complaint did not allege that the landlord or contractor undertook repairs or performed any negligent acts—only that they inspected and confirmed the leak. The court concluded Virginia law does not impose a tort duty on landlords for failing to repair, but only for negligent acts in the course of repair. The breach of contract claim survived the motion to dismiss, but the parties later stipulated to voluntarily dismiss it to allow an immediate appeal.The United States Court of Appeals for the Fourth Circuit first determined it had appellate jurisdiction, accepting the tenant's binding representation that she was abandoning the contract claim with prejudice. The court then affirmed the district court’s dismissal of the negligence claim. It held that, under Virginia law, a landlord is not liable in tort for failing to make repairs unless the landlord undertakes repairs and does so negligently. Because the complaint did not allege any negligent repair or positive act, only nonfeasance, the negligence claim failed as a matter of law. View "Metz v. McCarthy" on Justia Law

The case involves an injury sustained by an individual while operating a forklift designed, manufactured, and distributed by a company. The injured party alleged that the forklift’s open operator compartment constituted a defective design, making the product unreasonably dangerous, and asserted that adding features such as a door or bumper would have prevented the accident. To support these claims, the injured party retained an expert witness to testify about the alleged defect and alternative, safer designs.In the Circuit Court of Jackson County, the defendant company filed motions both to exclude the plaintiff’s expert witness and for summary judgment. The court found that the expert’s testimony lacked reliability, as the plaintiff failed to demonstrate that the expert’s opinions were based on reliable principles and methods, or that those methods had been properly applied to the facts. The court noted the absence of relevant testing, peer-reviewed support, or clear connection between the expert’s analysis and the incident. Consequently, the court excluded the expert’s testimony. Without admissible expert evidence to support the defective design claim, the circuit court then granted summary judgment for the company, as there was no genuine issue of material fact.On appeal, the Supreme Court of Missouri reviewed only the grant of summary judgment. The court held that the circuit court did not abuse its discretion in excluding the expert’s testimony under section 490.065, as the plaintiff failed to establish the reliability of the expert’s methods or their application to the case. The Supreme Court of Missouri affirmed the circuit court’s judgment, holding that without admissible expert testimony, summary judgment was proper, including as to the punitive damages claim, because the plaintiff could not prevail on the underlying product liability claim. View "Hanshaw v. Crown Equipment Corp." on Justia Law

Two former residents of Libby, Montana developed mesothelioma after being exposed to asbestos. The exposure was linked to asbestos-containing vermiculite transported by BNSF Railway Company from a nearby mine. Between 1922 and 1990, BNSF was required by federal law to ship this vermiculite to and from its Libby railyard. Evidence showed that asbestos dust escaped from sealed railcars during transit and switching operations, eventually accumulating in and around the railyard. Both plaintiffs resided or spent considerable time near the railyard during the relevant period.This litigation began when the personal representatives of the decedents’ estates brought negligence and strict liability claims against BNSF in the United States District Court for the District of Montana. BNSF moved for summary judgment on the strict liability claims, arguing that it was protected by the common carrier exception, but the district court denied the motion. After a jury trial, the jury found for BNSF on negligence but for the plaintiffs on strict liability, awarding compensatory damages. The district court subsequently denied BNSF’s renewed motion for judgment as a matter of law on the strict liability claims, prompting BNSF’s appeal.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of Montana law de novo. The Ninth Circuit held that the district court erred by applying the common carrier exception too narrowly. The appellate court concluded that BNSF’s transportation of asbestos-containing vermiculite, including the resulting accumulation of asbestos dust, was conducted pursuant to its federally mandated duty as a common carrier. Montana law, including recent precedent from the Montana Supreme Court, supported applying the common carrier exception to shield BNSF from strict liability in these circumstances. The Ninth Circuit reversed the district court’s judgment and remanded with instructions to enter judgment for BNSF. View "Wells v. BNSF Railway Co." on Justia Law

The parents of a young child in Texas purchased and fed him baby food manufactured by one company and sold by another. After the child began exhibiting serious developmental and physical disorders, doctors attributed his condition to heavy-metal poisoning. Years later, a congressional subcommittee released a report identifying elevated levels of toxic heavy metals in certain baby foods, including that manufactured by the company in question. The parents then sued both the manufacturer and the retailer in Texas state court, alleging various state-law product liability, negligence, and breach-of-warranty claims.The manufacturer, a Delaware corporation with its principal place of business in New York, removed the case to federal court, arguing that the retailer—a Texas citizen like the plaintiffs—had been improperly joined and should be dismissed, thereby creating complete diversity. The United States District Court agreed, dismissed the retailer, denied the plaintiffs’ motion to remand, and proceeded to trial against the manufacturer alone. After trial, the District Court granted judgment as a matter of law to the manufacturer. On appeal, the United States Court of Appeals for the Fifth Circuit disagreed with the District Court’s finding of improper joinder, reversed the dismissal of the retailer, and concluded that because the retailer was a proper party, complete diversity was lacking. The Fifth Circuit vacated the judgment and remanded the case to state court.The Supreme Court of the United States held that the District Court’s erroneous dismissal of the nondiverse defendant did not cure the jurisdictional defect present at the time of removal. Because the jurisdictional defect was not cured and persisted through final judgment, the federal court’s judgment had to be vacated. The Supreme Court affirmed the Fifth Circuit’s decision and remanded the case for further proceedings. View "Hain Celestial Group, Inc. v. Palmquist" on Justia Law

The case involves a personal injury claim arising from an automobile accident in which the plaintiff was rear-ended by the defendant while merging onto a roadway. Both parties testified that the collision caused minimal damage, and the plaintiff received brief medical attention before being released from care. The plaintiff had a prior history of back surgery but denied recent issues before the incident. The defendant admitted liability for the accident but contested whether his negligence was the proximate cause of the plaintiff's alleged injuries.The Desoto County Circuit Court presided over the trial. Prior to trial, the court granted in part the defendant’s motion to exclude “reptile theory” and “golden rule” arguments, preventing the plaintiff from making references at trial to the defendant’s personal sense of safety or knowledge of traffic rules in a way intended to evoke juror emotion. At trial, the court sustained objections to several questions by the plaintiff’s counsel regarding the defendant’s understanding of traffic rules and safety responsibilities. The jury was instructed that the defendant was negligent but that the plaintiff had to prove his negligence proximately caused her injuries. The jury returned a unanimous verdict for the defendant, finding the plaintiff failed to establish proximate cause. The plaintiff appealed, but did not file a motion for a new trial.The Supreme Court of Mississippi reviewed the case. It held that because the plaintiff did not file a motion for a new trial, appellate review of whether the jury’s verdict was against the overwhelming weight of the evidence was barred. The court also found that the trial court did not abuse its discretion by excluding the plaintiff’s “reptile theory” questioning, as such arguments were inadmissible under Mississippi Rules of Evidence 401 to 403. The judgment of the circuit court was affirmed. View "Greer v. Key" on Justia Law

This case involves four individuals who died by suicide after ingesting high-purity sodium nitrite purchased through Amazon’s website. The families and estates of the decedents allege that Amazon sold sodium nitrite without age verification or adequate warnings, promoted related products that facilitated suicide, and continued selling the chemical despite knowing it was being used for suicide. Plaintiffs contend that Amazon’s actions enhanced the risk of harm and demonstrated knowledge of the product’s misuse, citing Amazon’s receipt of warnings from consumers, regulatory agencies, and the removal of the product in other jurisdictions.The Superior Court denied Amazon’s motions to dismiss under CR 12(b)(6), finding that the plaintiffs had sufficiently stated a claim for negligence under the Washington Product Liability Act (WPLA). On appeal, the Court of Appeals, Division One, reversed this decision. The appellate court concluded that, under Washington law, suicide is typically a superseding cause that breaks the chain of proximate causation for negligence, barring recovery unless the suicide was involuntary or due to an uncontrollable impulse. Relying on precedent, the appellate court held that plaintiffs could not state a WPLA claim because suicide was a superseding cause as a matter of law.The Supreme Court of the State of Washington reviewed the case de novo. It determined that common law principles of negligence and proximate cause, including those developed after the WPLA’s enactment, govern product seller liability claims. The court held that, at the motion to dismiss stage, it cannot be said as a matter of law that suicide is always a superseding cause precluding liability under the WPLA. The court concluded that plaintiffs alleged sufficient facts to state a claim for product seller negligence, as questions of foreseeability and proximate cause are generally issues for the fact finder. The court reversed the Court of Appeals and reinstated the trial court’s denial of Amazon’s motions to dismiss. View "Scott v. Amazon.com, Inc." on Justia Law

A hotel guest staying in Manhattan communicated to his wife and sister, both out of state, that he intended to commit suicide. Alarmed, his family members called the hotel, first requesting that staff check on him in his room. Hotel personnel confirmed his immediate safety but noted possible warning signs such as empty liquor bottles and pill containers. After receiving further concerning messages from the guest, the family called the hotel again, identifying the situation as an escalating mental health emergency and requesting that the police be contacted immediately. Hotel staff agreed to call the police but delayed for over 20 minutes, during which the family, relying on the hotel’s assurances, did not contact emergency services themselves. Once police arrived, there was a further delay in accessing the guest’s room, and ultimately, the guest died by suicide.The decedent’s wife and mother, acting individually and as estate administrators, brought a negligence and wrongful death suit against the hotel’s owner and operator in New York Supreme Court. They claimed the hotel assumed a duty to take preventive measures—including contacting police—by agreeing to the family’s requests, and that the hotel’s delay caused a lost opportunity to prevent the suicide. The Supreme Court denied the hotel’s motion for summary judgment, finding issues of fact regarding whether any assumed duty was performed with due care. The Appellate Division reversed, granting summary judgment to the defendants and dismissing the complaint, holding that the hotel did not assume a duty to prevent the suicide, and even if it had, that duty was satisfied.On appeal, the New York Court of Appeals affirmed the Appellate Division’s order. The Court held that while the hotel may have assumed a duty to check on the guest, it satisfied any such duty, and it did not assume a duty to immediately call emergency services. The Court found that it was not reasonably foreseeable the family would forgo other means of seeking help and that no assumed duty arose under the circumstances. View "Beadell v Eros Mgt. Realty LLC" on Justia Law

Jeremy Starr, a delivery driver for Graybar Electric, claimed workers’ compensation for a back injury sustained in March 2018 while unloading pipes. Starr had a history of lumbar issues stemming from a 2004 motor vehicle accident, including a disc herniation documented by MRI. After his workplace injury, Starr underwent further imaging and treatment, ultimately receiving lumbar fusion surgery in 2022. Medical opinions diverged: some attributed the need for surgery to degenerative changes originating from the earlier accident, while others suggested the work injury was a significant cause. Starr provided additional evidence, including new medical evaluations and a deposition from his surgeon, to argue the surgery was compensable.The Administrative Law Judge (ALJ) initially found Starr suffered only a lumbar strain from the workplace incident and ruled the fusion surgery was not work-related, thus non-compensable. The ALJ awarded temporary total disability benefits for a limited period and later amended the award upon reconsideration. The Workers’ Compensation Board affirmed the ALJ’s findings, concluding that any factual misstatement was not so unreasonable as to compel a different result and that new evidence submitted by Starr did not meet the standard for “newly-discovered evidence,” having been available with due diligence.The Court of Appeals reversed, holding that the ALJ should have considered Starr’s additional evidence and correcting factual misstatements, reasoning that interlocutory orders are not final and that contested issues remained open for adjudication. Upon review, the Supreme Court of Kentucky reversed the Court of Appeals and reinstated the Board’s decision. The Supreme Court held that under Bowerman v. Black Equipment Co., dispositive interlocutory factual findings cannot be reversed in a subsequent final opinion absent newly-discovered evidence, fraud, or mistake. The Court found no gross injustice from the ALJ’s factual misstatement and determined the additional evidence was merely cumulative and not newly discovered. View "GRAYBAR ELECTRIC V. STARR" on Justia Law

A patient was admitted to a hospital after suffering chest pains and remained hospitalized for three months until his death. During his stay, he developed a severe Stage 4 sacral ulcer. The patient’s widow, acting individually and as personal representative of his estate, filed suit against the hospital and associated medical providers for negligence and medical malpractice, alleging that failures in wound care, skin monitoring, and repositioning caused the ulcer and contributed to his suffering and death. She also asserted a claim for lack of informed consent regarding risks of long-term hospitalization.The case was first reviewed by the Superior Court of the District of Columbia. During proceedings, the plaintiff shifted her theory to res ipsa loquitur, arguing that negligence could be inferred solely from the development of a Stage 4 ulcer during hospitalization. The Superior Court rejected application of res ipsa loquitur, expressing skepticism about the informed consent claim, and granted summary judgment for the defendants. The court also excluded the plaintiff’s expert testimony but gave little explanation for its reasoning.On appeal, the District of Columbia Court of Appeals conducted de novo review and affirmed the Superior Court’s judgment. The appellate court held that the plaintiff failed to establish a triable res ipsa loquitur case because her experts did not sufficiently address the patient’s multiple comorbidities, which were shown by defense evidence to have contributed to the unavoidable development and worsening of the ulcer. The court also held that the lack of informed consent claim failed due to the absence of expert testimony establishing that long-term hospitalization posed distinct risks compared to alternative care, or that the patient had a meaningful choice. Thus, summary judgment for the defendants was affirmed. View "Pearson v. Medstar Washington Hospital Center" on Justia Law

A resident of a retirement community, who has celiac disease and relies on a gluten free diet, experienced multiple episodes of illness after consuming meals labeled as gluten free at the facility. She signed a residential contract based on assurances that her dietary needs would be accommodated. Over several years, she reported incidents of illness to staff, including a crab cake in 2018, a stuffed tomato in 2020, and chicken marsala in 2021, all purportedly gluten free. The facility made various adjustments in response to her complaints, including menu changes, staff training, and kitchen modifications. She continued to use her meal plan but gave away the food. In 2023, she filed suit alleging violations of federal disability rights statutes and several state-law claims.The United States District Court for the District of Maryland granted summary judgment to the retirement community on all claims. The court found her federal claims untimely and denied her request for injunctive relief, concluding she lacked standing. It also rejected her state-law breach of contract and negligence claims, holding they were barred by the statute of limitations and unsupported by evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s judgment as to the federal claims, holding that the plaintiff lacked standing for injunctive relief under the Americans with Disabilities Act and that her Fair Housing Act and Rehabilitation Act claims were barred by the applicable statutes of limitations. It also affirmed dismissal of state-law claims related to the 2018 incident. However, the court vacated summary judgment as to her breach of contract and negligence claims arising from the January 2021 chicken marsala incident, finding genuine issues of material fact that should be resolved by a jury. The case was remanded for further proceedings on those claims. View "McGinn v. Broadmead, Inc." on Justia Law