Bertola v. Fisher-Price

Superior Court of Delaware·Decided April 21, 2025·No. N21C-01-115 FJJ·Published

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

SARAH ANN BERTOLA and ) DALLAS BERTOLA, ) Co-Personal Representatives of the ) C.A. No. N21C-01-115 FJJ Estate of A.M.B., Deceased ) and in their own right )

Plaintiffs, )

)

v. )

)

FISHER-PRICE, INC., and ) MATTEL, INC., )

Defendants. )

Submitted: April 11, 2024 Decided: April 21, 2025

OPINION AND ORDER

On Defendants’ Motion for Summary Judgment on the Statute of Limitations DENIED

Robert J. Leoni, Esquire, Shelsby & Leoni, Newark, Delaware and Alan M. Feldman, Daniel J. Mann, and Edward S. Goldis, Esquires, (Pro Hac Vice) Feldman Shepherd Wohlgelernter Tanner Weinstock & Dodig, LLP, Philadelphia, Pennsylvania, Attorneys for Plaintiffs.

Jennifer C. Wasson, Esquire, and Ryan D. Kingshill, Esquire, Potter Anderson & Corroon, LLP, Wilmington, Delaware, and Amy Furness, Esquire, (Pro Hac Vice) Carlton Fields, P.A., Miami, Florida and Robert Shannon, Esquire, (Pro Hac Vice Carlton Fields, P.A., Atlanta, Georgia, Attorneys for Defendants.

Jones, J.

INTRODUCTION

Plaintiffs, Sarah Ann Bertola and Dallas Bertola on behalf of themselves and as representatives of A.M.B’s estate (hereinafter “Plaintiffs”), bring product liability claims against Defendants, Fisher-Price and Mattel, Inc., for the death of their infant child, A.M.B. Plaintiffs allege A.M.B. asphyxiated and suffocated while sleeping in Defendants’ Rock ‘N Play Sleeper (hereinafter “RnP”). Plaintiffs claim product deficiencies and improper marketing and sale of the RnP as a safe product for an infant to sleep in unattended caused A.M.B’s death. Defendants bring the instant Motion for Summary Judgment asking the Court to conclude that Plaintiffs’ claims are barred by the applicable statute of limitations.

FACTS AND PROCEDURAL HISTORY A. The Rock ‘N Play Sleeper (“RnP”)

The RnP was sold as “an inclined sleeping product” intended for day or overnight sleep “in which infants are placed supine (on their backs) at less than a 30- degree angle from the horizontal.”1 The product consists of a “free-standing metal rocking frame, an attached rigid plastic backing, a removable seat pad with fabric cover, and a three-point belt restraint system.”2 The restraint system “secured a strap between the infant’s legs and across the torso.”3

1 Docket Item (“D.I.”) 164, Ex. B, Aff. of Jennifer Mussell, 1/30/24. 2 Id. 3 Id.

B. The Incident Sarah Bertola, A.M.B.’s mother, received her RnP as a baby shower gift from her sisters.4 In the evening of January 4, 2017, Ms. Bertola put A.M.B. to sleep in the RnP on her back and swaddled in a blanket.5 The restraint system was not being used due to A.M.B.’s swaddle hindering it.6 The RnP was located in A.M.B.’s nursery.7 Ms. Bertola then went to her bedroom to watch TV with her husband, A.M.B.’s father, Dallas Bertola.8 Around 2:00 in the morning, Ms. Bertola checked on A.M.B, who appeared to be fine, and placed a blanket around her waist.9 At 10:10 in the morning on January 5, 2017, Ms. Bertola woke up concerned she had not heard A.M.B.10 When she went to check on A.M.B., she found her “slumped down in the RNPS with her head tilted downwards to the right and her chin on her shoulder.”11 The blanket Ms. Bertola had placed on A.M.B. in the middle of the night was now “covering A.M.B.’s face up to the pacifier that was in her mouth.”12 Ms. Bertola yelled out to her husband in their bedroom and attempted CPR. 13 Emergency authorities were called to the scene but could not revive A.M.B.14 The infant’s death

4 D.I. 164 p. 8. 5 D.I. 194 p. 12. 6 D.I. 164 p. 9. 7 Id. 8 Id. 9 D.I. 194 p. 12-13. 10 Id. at 13. 11 Id., Ex. BB, Sarah Bertola Dep. at 256-57. 12 Id., Ex. BB at 191-92. 13 Id. 14 Id.

was ruled by the autopsy report as a “Sudden Unexplained Infant Death” with a caused that “Could Not Be Determined.”15 C. Facts for Inquiry Notice and Tolling Doctrine Arguments In January of 2017,16 Ms. Bertola made online blog posts after the death of A.M.B.17 In one blog post Ms. Bertola stated that, “...there are some people who believe having a baby sleep in these all night is unsafe.”18 She also made a blog post stating: “However, I personally believe (and the police and my doctor have agreed with me) that [the RNPS] had nothing to do with her passing.”19 There were also comments made on her blog by laypersons questioning the safety of the Rock ‘N Play Sleeper.20 In March of 2018, the Consumer Product Safety Commission’s (“CPSC”)

contacted Ms. Bertola, interviewed both parents, took possession of the Rock ‘N Play Sleeper, and made a report.21 In April of 2019, the Rock ‘N Play Sleeper was recalled by Defendant.22 Defendants stated that “[i]nfant fatalities have occurred in Rock ‘n Play Sleepers.”23 In January of 2023, Defendants reannounced the recall.24

15 D.I. 164 p. 1, Ex. A at 1. 16 Id. at 5, 19. 17 D.I. 196 p. 19. 18 D.I. 160 p. 18, Ex. M. 19 D.I. 196 p. 19, Ex. E; see also Exs. F; G. 20 D.I. 160 p. 4, 18. 21 D.I. 160 p. 2, 19, see also Exs. C; J. 22 Id. p. 3. 23 D.I. 196 p. 3, Ex. A. 24 Id. 4-6, Ex. F.

D. Procedural History Plaintiffs filed suit on January 15, 2021.25 Defendants filed the instant Motion for Summary on January 31, 2024.26 Full briefing has concluded with Plaintiffs filing their Answering Brief in Opposition on March 11, 2024 27 and Defendants filing their Reply Brief on April 11, 2024.28 The larger than usual period of time between briefing and this opinion is due to continuances in this case as well as in the litigation involving the product in general.

CHOICE OF LAW

The accident initiating this case occurred in Utah. The parties agree that Utah substantive law applies to this case,29 and this Court will so apply it. The general rule is to apply procedural law of the forum.30 In the instant case, the forum is Delaware; therefore, Delaware procedural law is applicable.

STANDARD OF REVIEW

Superior Court Civil Rule 56(c) states a party seeking summary judgment must show “there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”31 A genuine issue of material fact

25 D.I. 1. 26 D.I. 160. 27 D.I. 196. 28 D.I. 214. 29 See D.I. 145, Stipulation and Order on Choice of Law. 30 Chaplake Holdings, Ltd. v. Chrysler Corp., 766 A.2d 1, 5 (Del. 2001). 31 Del. Super. Ct. Civ. R. 56(c).

is one that “may reasonably be resolved in favor of either party.”32 The court views the evidence provided “in a light most favorable to the non-moving party.”33 The initial burden is on the moving party to show there are no genuine issues of material fact.34 The burden then shifts to the non-moving party to show there is at least one material issue of fact in dispute.35 The court must consider “the pleadings, depositions, answers to interrogatories, and admissions on file, together with affidavits, if any,” in determining whether there is a genuine issue as to any material fact, and the court must “accept all undisputed factual assertions and accept the nonmoving party’s version of any disputed facts.”36 However, any factual inferences made in favor of the non-moving party must be reasonable.37 When a summary judgment motion is premised on a statute of limitations argument, a court must grant the motion, “if the record reveals that no genuine issue of fact exists regarding the date on which the applicable statute of limitations began to run, the date to which the statute of limitations may have been tolled, and the date on which the plaintiff filed [the] complaint with the court.”38 “When a complaint asserts a cause of action that on its face accrued outside the statute of limitations,

32 Saunders v. Lightwave Logic, Inc., 2024 WL 4512227, at *6 (Del. Super. Oct. 17, 2024). 33 Gibson v. Metro. Grp. Prop. And Casualty Ins. Co., 2017 WL 5606714, at *2 (Del. Super. Nov. 15, 2017). 34 Id. 35 Id. 36 Coker v. Tenney-Andrews, 2016 WL 6659500, at *2 (Del. Super. Nov. 10, 2016). 37 Smith v. Haldeman, 2012 WL 3611895, at *1 (Del. Super. Aug. 21, 2012). 38 Saunders, 2024 WL 4512227, at *6 (quoting Burrell, 2010 WL 3706584, at *2).

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