Camacho v. Ford Motor Company

District Court, W.D. Texas·Decided April 23, 2020·No. 5:19-cv-00023·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

JOSE L. CAMACHO et al., § § Plaintiffs, § § v. § Civil Action No. SA-19-CV-23-XR § FORD MOTOR COMPANY, § § Defendant. § § §

ORDER ON MOTION TO AMEND JUDGMENT

On this date, the Court considered Plaintiffs’ motion to amend judgment pursuant to Federal Rule of Civil Procedure 59(e) (docket no. 49) and Defendant’s response (docket no. 52). For the following reasons, Plaintiffs’ motion is DENIED. BACKGROUND Plaintiffs Jose, Maria, Fabian, and Luis Camacho (collectively, “Plaintiffs”) brought this products liability action after a rollover crash of a Ford truck on August 6, 2017 near Nuevo Laredo, Mexico. Docket no. 44 at 1. Plaintiffs brought suit against Ford, claiming strict products liability and negligence. Docket nos. 1, 32. On January 16, 2020, this Court granted Defendant’s motion for summary judgment, finding that Plaintiffs’ claims were time-barred by the Texas statute of repose for products liability actions, which reads: Except as provided by Subsections (c), (d), and (d–1), a claimant must commence a products liability action against a manufacturer or seller of a product before the end of 15 years after the date of sale of the product by the defendant.

TEX. CIV. PRAC. & REM. CODE § 16.012(b). The Court found that the relevant “date of sale” triggering the 15-year deadline was October 6, 2003. Docket no. 44 at 10. Plaintiffs brought suit on January 10, 2019, so the Court found the action was time-barred because more than 15 years passed since the date of sale by the defendant. Id. at 11. The Court further found that the statute of repose was not tolled for Plaintiff Fabian Camacho’s minority age at the time of the accident. Id at 11–12. On that same date, January 16, 2020, the Clerk entered judgment in favor of Defendant. Docket no. 45. Plaintiffs then timely filed this Rule 59(e) motion seeking an alteration or

amendment to the Court’s judgment. DISCUSSION I. Standard of Review Federal Rule of Civil Procedure 59(e) allows a court “to prevent a manifest injustice” by altering or amending a judgment upon a timely motion. FED. R. CIV. P. 59(e); Schiller v. Physicians Res. Grp., Inc., 342 F.3d 563, 567 (5th Cir. 2003). There are three limited circumstances in which such a motion may be granted: (1) to correct a manifest error of law or fact, (2) to account for newly discovered evidence, or (3) to accommodate an intervening change in controlling law. Demahy v. Schwarz Pharma, Inc., 702 F.3d 177, 182 (5th Cir. 2012). The only ground alleged in

this case is “manifest error.” To find such an error, the error must be “plain and indisputable” and one “that amounts to a complete disregard of the controlling law.” Lyles v. Medtronic Sofamor Danek, USA, Inc., 871 F.3d 305, 311 (5th Cir. 2017), cert. denied, 138 S. Ct. 1037 (2018). A Rule 59(e) motion “cannot be used to raise arguments which could, and should, have been made before the judgment issues.” Simon v. United States, 891 F.2d 1154, 1159 (5th Cir. 1990). Nor can it be used to “relitigate old matters” that have already been resolved. Exxon Shipping Co. v. Baker, 554 U.S. 471, 485 n.5 (2008) (quoting 11 C. WRIGHT & A. MILLER, FEDERAL PRACTICE AND PROCEDURE § 2810.1 (2d ed. 1995)); see also Templet v. HydroChem, Inc., 367 F.3d 473, 479 (5th Cir. 2004) (“[S]uch a motion is not the proper vehicle for rehashing evidence, legal theories, or arguments that could have been offered or raised before the entry of judgment.”). A Rule 59(e) motion “calls into question the correctness of a judgment” and “is an extraordinary remedy that should be used sparingly.” Id. at 478–79 (internal citations omitted). A court, in considering such a motion, must balance “the need to bring litigation to an end” and “the need to render just decisions on the basis of all the facts.” Id. at 479. Though the court must

consider these competing interests, Rule 59(e) favors the denial of a motion to alter or amend a judgment. S. Constructors Grp., Inc. v. Dynalectric Co., 2 F.3d 606, 611 (5th Cir. 1993). II. Analysis In their motion, Plaintiffs argue that the Court should amend its granting of summary judgment due to a “manifest error.” They argue that Defendant selectively cited relevant facts, ignored others, and misapplied the law to those facts. Docket no. 49 at 2. In addition, they argue, Defendant relied on hearsay and conclusory, contradictory testimony from Defendant’s corporate representatives. Id.1 As to the merits, Plaintiffs argue that the Court was incorrect in finding that the wholesale or “release” date was the relevant date of sale under the Texas statute of repose.2

Plaintiffs contend that the relevant date is either the date of titling or registration of the vehicle as

1 Plaintiffs raised these same evidentiary arguments at the summary judgment stage, and the Court rejected each. See docket no. 44 at 2–3, n. 2–4. The same goes for Plaintiffs’ arguments that Defendant’s evidence is “contradictory and unproven.” Plaintiffs already raised those same arguments, used the same evidentiary support, and relied on the same cases to argue as such. A Rule 59(e) motion is not intended to “rehash” the same arguments and same facts that have already been presented to the Court for consideration. Templet, 367 F.3d at 479. 2 Plaintiffs’ motion states that “The relevant ‘date of sale’ under the Texas products liability statute of repose is the date of first sale.” Docket no. 49 at 3. This rather starkly omits the crucial phrase “by the defendant” as found in the Texas products liability statute of repose—a phrase the Court found to be critical insofar as it distinguishes Texas’s statute of repose from other states’ consumer-centric statutes. See docket no. 44 at 7 (citing Dalfrey v. Boss Hoss Cycles, Inc., 456 F. App’x 329, 332 (5th Cir. 2011)). Other states fix the statutory period, for example, “after the date of initial purchase for use or consumption,” but Texas fixes the period at the “date of sale by the defendant.” Id. at 333 (quoting N.C. GEN. STAT. § 1– 50(6)(2008) and TEX. CIV. PRAC. & REM. CODE §16.012(b) (emphasis added)). set forth in the Certificate of Title Act, a provision in the Texas Transportation Code. Id. at 15. Under the Plaintiffs’ proposed analysis, the “date of sale” for purposes of the statute of repose would be within the 15-year statute of repose deadline as set forth in Section 16.012 of the Texas Civil Practice and Remedies Code. Id. at 3, 6.

Plaintiffs, however, have already presented these same arguments to the Court, and the Court has rejected them. Indeed, much of the language in Plaintiffs’ motion is drawn directly— verbatim—from their response to Defendant’s motion for summary judgment. Compare docket no. 49 ¶ 3 with docket no. 29 ¶ 2. Plaintiffs have already proposed that the Texas Certificate of Title Act supplies the relevant date of sale, and the Court rejected that theory. Docket no. 44 at 8– 10.

Free access — add to your briefcase to read the full text and ask questions with AI

Camacho v. Ford Motor Company, (W.D. Tex. 2020).

Camacho v. Ford Motor Company (Camacho v. Ford Motor Company) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related