Apodaca v. Eaton Corporation

District Court, W.D. Washington·Decided February 23, 2023·No. 2:20-cv-01064·Unknown

Opinion

1 2 UNITED STATES DISTRICT COURT AT SEATTLE 4 5 EDGAR GUERRERO APODACA, CASE NO. 2:20-cv-01064-TL 6 Plaintiff, ORDER DENYING v. 7 DEFENDANT’S MOTION FOR EATON CORPORATION, RECONSIDERATION 8 Defendant. 9 10 DAVID FITZPATRICK, and RYAN MCDADE, 11 Intervention Plaintiffs, 12 v. 13 EATON CORPORATION, 14 Intervention Defendant 15 16 This matter is before the Court on Defendant Eaton Corporation’s (“Eaton”) Motion for 17 Reconsideration. Dkt. No. 115. Plaintiffs were injured while working on a construction site when 18 a piece of electrical equipment manufactured by Eaton exploded. Dkt. Nos. 21, 25. Plaintiffs’ 19 suits assert manufacturing and design defect claims, as well as a failure to warn claim under the 20 Washington Product Liability Act (“WPLA”). Id.; see also RCW 7.72 et seq. Plaintiffs moved 21 for partial summary judgment on Eaton’s liability for their respective claims and for dismissal of 22 Eaton’s contributory fault defense. Dkt. Nos. 57, 87. The Court granted Plaintiffs summary 23 judgment as to Eaton’s liability for failure to warn but denied summary judgment as to the 24 remaining issues. Dkt. No. 108. Eaton now moves for reconsideration of the Court’s Order 1 granting summary judgment on Intervenor Plaintiffs’ failure to warn claims.1 Dkt. No. 115. 2 Having considered the relevant record and finding responsive briefing unnecessary, see 3 LCR 7(h)(3), the Court DENIES Eaton’s motion for reconsideration.

5 “Motions for reconsideration are disfavored.” LCR 7(h)(1). Such motions must be denied 6 absent a showing of “manifest error in the prior ruling or . . . new facts or legal authority which 7 could not have been brought to [the Court’s] attention earlier with reasonable diligence.” Id. 8 Motions for reconsideration should be granted only in “highly unusual circumstances.” Marlyn 9 Nutraceuticals, Inc. v. Mucos Pharma GmbH & Co., 571 F.3d 873, 880 (9th Cir. 2009) (quoting 10 389 Orange St. Partners v. Arnold, 179 F.3d 656, 665 (9th Cir. 1999)). “A motion for 11 reconsideration ‘may not be used to raise arguments or present evidence for the first time when 12 they could reasonably have been raised earlier in the litigation.’” Id. (quoting Kona Enters., Inc. 13 v. Estate of Bishop, 229 F.3d 877, 890 (9th Cir. 2000)). “Whether or not to grant reconsideration 14 is committed to the sound discretion of the court.” Navajo Nation v. Confederated Tribes &

15 Bands of the Yakima Indian Nation, 331 F.3d 1041, 1046 (9th Cir. 2003). 17 Eaton assigns error to the Court’s decision on summary judgment. Summary judgment is 18 appropriate where “the movant shows that there is no genuine dispute as to any material fact and 19 the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). Once the movant 20 21 1 Plaintiff Edgar Guerrero Apodaca originally joined the summary judgment motion filed by Intervenor Plaintiffs 22 David Fitzpatrick and Ryan McDade. Dkt. No. 87. While the motion was pending, the Court received notice that Eaton and Mr. Apodaca had reached a settlement agreement. Dkt. No. 97. The Parties stipulated to the dismissal of all of Mr. Apodaca’s claims (Dkt. No. 110), and an order of dismissal was entered (Dkt. No. 111) after the Court’s 23 Order on Plaintiff’s Motion for Partial Summary Judgment was entered (Dkt. No. 108). Thus, this Order denying reconsideration is applicable only to the Court’s grant of summary judgment as to liability on Intervenor Plaintiffs’ 24 failure to warn claims. 1 has made such a showing, “its opponent must do more than simply show that there is some 2 metaphysical doubt as to the material facts.” Matsushita Elec. Indus. Co., Ltd. v. Zenith Radio 3 Corp., 475 U.S. 574, 586 (1986) (citation omitted); accord Anderson v. Liberty Lobby, Inc., 477 4 U.S. 242, 252 (1986) (specifying that the non-movant “must show more than the mere existence

5 of a scintilla of evidence”); In re Oracle Corp. Secs. Litig., 627 F.3d 376, 387 (9th Cir. 2010). 6 The non-movant “bears the burden of production under [FRCP] 56 to ‘designate specific facts 7 showing that there is a genuine issue for trial.’” Ricci v. DeStefano, 557 U.S. 557, 586 (2009) 8 (quoting Celotex Corp. v. Catrett, 477 U.S. 317, 324 (1986)). 9 On summary judgment, the Court does not make credibility determinations, nor does it 10 weigh the evidence. Liberty Lobby, 477 U.S. at 255; accord Munden v. Stewart Title Guar. Co., 11 8 F.4th 1040, 1044 (9th Cir. 2021). As many of Eaton’s arguments appear to turn on whether the 12 Court made inappropriate inferences based on the evidence presented on summary judgment (see 13 Dkt. No. 115 passim), the Court reiterates that the applicable standard on summary judgment 14 requires that “all justifiable inferences must be drawn in the non-movant’s favor . . . only []

15 where the facts specifically averred by the non-moving party contradict facts specifically averred 16 by the movant.” Dkt. No. 108 at 6 (emphasis added) (citations and internal quotation marks 17 omitted). 18 Eaton argues that the Court manifestly erred in granting summary judgment on the failure 19 to warn claims by disregarding evidence presented in opposition to summary judgment and 20 drawing inferences that “invert[] the Rule 56 standard.” Dkt. No. 115 at 2. Specifically, Eaton 21 assigns error to the Court’s rulings (1) that the warning instructions Eaton provided on its 22 equipment were inadequate as a matter of law and (2) that the inadequate instructions were the 23 proximate cause of Plaintiffs’ injuries. Id. The Court finds no error in its prior rulings on these

24 issues. 1 A. Inadequacy of Eaton’s Warning Instructions 2 The Court ruled that the warning instructions provided by Eaton are inadequate as a 3 matter of law given “the likelihood of serious injury from an arc flash incident occurring if either 4 side of the bus plug were worked on while the busway was energized.” Dkt. No. 108 at 9.

5 Contrary to Eaton’s claim that the Court disregarded contrary evidence, the Court thoroughly 6 considered the entire record and relied primarily on evidence provided by Eaton in opposition to 7 summary judgment in reaching its ruling. Id. at 9–10. 8 Eaton first argues that the Court made an erroneous inference regarding the warning 9 instructions—i.e., that the court conflated “sufficient” warnings with “necessary” warnings in 10 concluding that Eaton failed to raise a dispute of fact as to the adequacy of the instructions—but 11 Eaton provides no legal support for its purported distinction. Id. at 4. To the contrary, the Court 12 found that the plain text of the warning instructions Eaton provided unambiguously states what is 13 required to safely work on either side of the bus plug; therefore, no inference regarding the 14 meaning of the instructions was necessary. Dkt. No. 108 at 9. Even if the Court’s understanding

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