Cincinnati Insurance v. Automatic Blanket Plant

750 F. Supp. 280, 1989 U.S. Dist. LEXIS 17210, 1989 WL 226519
CourtDistrict Court, S.D. Ohio
DecidedMay 5, 1989
DocketNo. C2-87-495
StatusPublished

This text of 750 F. Supp. 280 (Cincinnati Insurance v. Automatic Blanket Plant) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cincinnati Insurance v. Automatic Blanket Plant, 750 F. Supp. 280, 1989 U.S. Dist. LEXIS 17210, 1989 WL 226519 (S.D. Ohio 1989).

Opinion

OPINION AND ORDER

GEORGE C. SMITH, District Judge.

This matter is before the Court on defendant, Automatic Blanket Plant’s motion for summary judgment.

Plaintiff, Cincinnati Insurance Company (hereinafter Cincinnati) brought this action against defendants Automatic Blanket Plant (Automatic) and J.C. Penney Company on March 20, 1987. This case was originally filed in the Common Pleas Court of Franklin County, Ohio. Pursuant to defendant’s petition and notice of removal filed April 21, 1987, this Court gained jurisdiction.

Plaintiff alleges that as a result of an electric blanket manufactured by Automatic and sold by J.C. Penney, a fire ensued to the residence of Richard and Peggy Armstrong. Plaintiff Cincinnati had an insurance contract with said Armstrong’s and subsequently had to pay for the damages [281]*281resulting from the fire. Cincinnati is sub-rogated to the rights of their insured.

Specifically, Cincinnati avers that the defendants breached their express and implied warranties, by selling and distributing a negligently designed and manufactured automatic electric blanket, which was defective and unreasonably dangerous. Plaintiff seeks seventy thousand ($70,000) dollars in damages.

STANDARD OF REVIEW

In considering this motion, the Court is mindful that the standard for summary judgment “mirrors the standard for a directed verdict under Rule 50(a), which is that the trial judge must direct a verdict if, under the governing law, there can be but one reasonable conclusion as to the verdict”. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986), citing Brady v. Southern Ry. Co., 320 U.S. 476, 479-480, 64 S.Ct. 232, 234, 88 L.Ed. 239 (1943). Thus, the Supreme Court concluded in Anderson that a judge considering a motion for summary judgment must “ask himself not whether he thinks the evidence unmistakably favors one side or the other but whether he thinks a fair-minded jury could return a verdict for the plaintiff on the evidence presented”. 477 U.S. at 252, 106 S.Ct. at 2512.

Rule 56(c) of the Federal Rules of Civil Procedure provides in pertinent part:

The judgment sought shall be rendered forthwith if the pleadings, depositions, answers to interrogatories, and admissions on file together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.

In essence, the inquiry is whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law. 477 U.S. at 252, 106 S.Ct. at 2512.

Such an inquiry necessarily implicates the evidentiary standard of proof that would apply at the trial on the merits. As a result, the Court must view the evidence presented through the prism of the substantive evidentiary burden. Rule 56(e), therefore, requires that the nonmoving party to go beyond the pleadings and by her own affidavits, or by the depositions, answers to interrogatories, and admissions on file, designate specific facts showing that there is a genuine issue for trial. Celotex Corp. v. Catrett, 477 U.S. 317, 324, 106 S.Ct. 2548, 2553, 91 L.Ed.2d 265 (1986). (Emphasis added). The plain language of Rule 56(c) mandates the entry of summary judgment after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish an element essential to the party’s case, and on which that party will bear the burden of proof at trial. Id. at 322, 106 S.Ct. at 2552. Thus, the mere existence of a scintilla of evidence in support of a plaintiffs claim is insufficient — there must be evidence upon which a jury could reasonably find for the plaintiff. Having addressed the Rule 56 standard of review, the Court now turns to the merits.

LAW AND ANALYSIS

The history of strict products liability in Ohio has again been reviewed by the Ohio Supreme Court in State Farm Fire and Casualty Co. v. Chrysler Corporation, 37 Ohio St.3d 1, 523 N.E.2d 489 (1988). Prior to that decision, Ohio had adopted Section 204A of the Restatement of the Law 2d, Torts (1965), which ultimately established the consumer expectation test. Temple v. Wean United, Inc., 50 Ohio St.2d 317, 364 N.E.2d 267 (1977). Applicable totally to both manufacturing and design defects, that standard allows for a product to be in a defective condition if it is more dangerous than an ordinary consumer would expect when used as intended or in a reasonably foreseeable manner. Leichtamer v. American Motors Corp., 67 Ohio St.2d 456, 424 N.E.2d 568 (1981). However, in State Farm (supra) Ohio’s Supreme Court firmly established that in manufacturing defects cases, plaintiff’s still had to show by a preponderance of the evidence, that the alleged defect was present when the product left the hands of the manufacturer [282]*282and the proximate cause of the claimed injuries. State Farm, 37 Ohio St.3d at 7, 523 N.E.2d 489. (Emphasis added). Further, the Court stated:

As in manufacturing defect cases, proof of liability in design defect cases still requires that the three elements of Lonzrick [v. Republic Steel Corp., 6 Ohio St.2d 227, 218 N.E.2d 185 (1966) ] be satisfied. Thus, first, under the consumer-expectation standard, evidence of unsafe, unexpected product performance is sufficient to infer the existence of a product defect. Next, absent substantial change in the condition in which the product was sold (e.g., Temple v. Wean United, Inc., supra, at paragraph one of the syllabus; King v. K.R. Wilson Co. [1983], 8 Ohio St.3d 9, 8 OBR 79, 455 N.E.2d 1282), it may also be inferred that the design defect was present when the product left the hands of the manufacturer. Finally, to fix liability for a design defect, it remains incumbent upon a plaintiff to establish the element of causation — to prove by a preponderance of the evidence that it was some aspect of the challenged design which rendered the product’s performance less safe than the ordinary consumer would expect, resulting in injury. Id.

The Ohio Supreme Court went on to add:

It is apparent that the expectation of the ordinary consumer, while accorded formal respect, is not the only element necessary to establish liability for design defects.... The causation requirement that is made explicit today maintains the distinction between strict liability based on design defects and absolute liability based upon injury. Id.

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

Related

Brady v. Southern Railway Co.
320 U.S. 476 (Supreme Court, 1944)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Delk v. Holiday Inns, Inc.
545 F. Supp. 969 (S.D. Ohio, 1982)
Lonzrick v. Republic Steel Corp.
218 N.E.2d 185 (Ohio Supreme Court, 1966)
Temple v. Wean United, Inc.
364 N.E.2d 267 (Ohio Supreme Court, 1977)
Leichtamer v. American Motors Corp.
424 N.E.2d 568 (Ohio Supreme Court, 1981)
King v. K.R. Wilson Co.
455 N.E.2d 1282 (Ohio Supreme Court, 1983)
State Farm Fire & Casualty Co. v. Chrysler Corp.
523 N.E.2d 489 (Ohio Supreme Court, 1988)

Cite This Page — Counsel Stack

Bluebook (online)
750 F. Supp. 280, 1989 U.S. Dist. LEXIS 17210, 1989 WL 226519, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cincinnati-insurance-v-automatic-blanket-plant-ohsd-1989.