American Strategic Insurance Corp. v. TTI Outdoor Power Equipment, Inc.

District Court, M.D. Pennsylvania·Decided August 26, 2026·No. 3:25-cv-01888·Unknown

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA AMERICAN STRATEGIC INSURANCE CORP., CIVIL ACTION NO. 3:25-CV-01888 Plaintiff, v. (MEHALCHICK, J.)

TTI OUTDOOR POWER EQUIPMENT, INC.,

Defendant. MEMORANDUM On April 23, 2025, Plaintiff American Strategic Insurance Corporation (“ASI”), as subrogee of Victor Saraceno and Christine Saraceno, initiated this action by filing a complaint in the Luzerne County Court of Common Pleas. (Doc. 1-2, at 2-9). On September 18, 2025, ASI filed the operative amended complaint in the Court of Common Pleas. (Doc. 1-2, at 49- 56). On October 8, 2025, Defendant TTI Outdoor Power Equipment, Inc. (“TTI”) removed this action to the Court on the basis of diversity jurisdiction. (Doc. 1). Presently before the Court is TTI’s motion to dismiss for failure to state a claim. (Doc. 5). For the following reasons, TTI’s motion is granted in part and denied in part. I. BACKGROUND AND PROCEDURAL HISTORY The following background is taken from the amended complaint and, for the purposes of the instant motion, is taken as true. (Doc. 1-2, at 49-56). ASI is a Florida corporation which insured the real and personal property of Victor Saraceno (“Victor”) and Christine Saraceno (“Christine”) (together, the “Insured”) at all times relevant to this action. (Doc. 1-2, at 49-50). ASI insured the Insured’s personal home located at 171 Grouse Ridge Lane, Drums, Pennsylvania 18222 (the “Subject Property”). (Doc. 1-2, at 50). TTI is a Delaware corporation which develops, manufactures, and distributes power tools, power tool batteries, and power tool accessories. (Doc. 1-2, at 50). The Insured lived at the Subject Property since 2012. (Doc. 1-2, at 50). Around June 2017, Victor purchased a Ryobi HP 40v Brushless Self-Propelled Lawn Mower from Home Depot which contained a 40v Ryobi lithium battery (the “Battery”). (Doc. 1-2, at 50). TTI

designed, manufactured, and sold the Battery. (Doc. 1-2, at 52). On March 2, 2024, the Battery caught on fire, causing damage to the Insured’s real and personal property. (Doc. 1- 2, at 51). The Battery was not charging at the time of the combustion, and Victor had not used the lawnmower since Fall of 2023. (Doc. 1-2, at 50-51). The Insured filed an insurance claim with ASI and ASI made a payment in excess of $386,925.96 to the Insured. (Doc. 1-2, at 51). On September 18, 2025, ASI filed the amended complaint alleging three counts under Pennsylvania law. (Doc. 1-2, at 49-56). In Count I, ASI alleges TTI is liable for negligence. (Doc. 1-2, at 52-53). In Count II, ASI alleges TTI is strictly liable for designing, assembling, manufacturing, selling, and/or distributing a defective product. (Doc. 1-2, at 53-55). In Count

III, ASI alleges TTI is liable for breach of implied warranties of merchantability and fitness for a particular purpose. (Doc. 1-2, at 55-56). II. LEGAL STANDARD Rule 12(b)(6) of the Federal Rules of Civil Procedure authorizes a defendant to move to dismiss for “failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). To assess the sufficiency of a complaint on a Rule 12(b)(6) motion, a court must first take note of the elements a plaintiff must plead to state a claim, then identify mere conclusions that are not entitled to the assumption of truth, and finally determine whether the complaint’s factual allegations, taken as true, could plausibly satisfy the elements of the legal claim. Burtch v. Milberg Factors, Inc., 662 F.3d 212, 221 (3d Cir. 2011). In deciding a Rule 12(b)(6) motion, the court may consider the facts alleged on the face of the complaint, as well as “documents incorporated into the complaint by reference, and matters of which a court may take judicial notice.” Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 308, 322 (2007).

After recognizing the required elements that make up the legal claim, a court should “begin by identifying pleadings that, because they are no more than conclusions, are not entitled to the assumption of truth.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). The plaintiff must provide some factual ground for relief, which “requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). “[T]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678. Thus, courts “need not credit a complaint’s ‘bald assertions’ or ‘legal conclusions’. . . ” Morse v. Lower Merion Sch. Dist., 132 F.3d 902, 906 (3d Cir. 1997) (quoting In re Burlington Coat

Factory Sec. Litig., 114 F.3d 1410, 1429-30 (3d Cir. 1997)). Nor need a court assume that a plaintiff can prove facts that the plaintiff has not alleged. Associated Gen. Contractors of Cal. v. Cal. State Council of Carpenters, 459 U.S. 519, 526 (1983). A court must then determine whether the well-pleaded factual allegations give rise to a plausible claim for relief. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Palakovic v. Wetzel, 854 F.3d 209, 219-20 (3d Cir. 2017) (quoting Iqbal, 556 U.S. at 678) (internal quotation marks omitted); see also Sheridan v. NGK Metals Corp., 609 F.3d 239, 262 n.27 (3d Cir. 2010). The court must accept as true all allegations in

the complaint, and any reasonable inferences that can be drawn therefrom are to be construed in the light most favorable to the plaintiff. Jordan v. Fox, Rothschild, O'Brien & Frankel, 20 F.3d 1250, 1261 (3d Cir. 1994). This “presumption of truth attaches only to those allegations for which there is sufficient factual matter to render them plausible on their face.” Schuchardt v. President of the U.S., 839 F.3d 336, 347 (3d Cir. 2016) (internal quotation and citation omitted).

The plausibility determination is context-specific and does not impose a heightened pleading requirement. Schuchardt, 839 F.3d at 347. III. DISCUSSION A. COUNT III IS BARRED BY THE STATUTE OF LIMITATIONS. In Count III, ASI alleges TTI is liable for breach of implied warranties of merchantability and fitness for a particular purpose. (Doc. 1-2, at 55-56). TTI contends that breach of warranty claims have a four year statute of limitations and the claims accrue at the time the relevant product is delivered. (Doc. 6, at 8). TTI avers that the Court must dismiss Count III because ASI alleges that the Insured received the Battery in 2017, more than four years before ASI filed its initial complaint. (Doc. 6, at 8-9). ASI acknowledges that TTI

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American Strategic Insurance Corp. v. TTI Outdoor Power Equipment, Inc., (M.D. Pa. 2026).

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