Cohen v. Key Automotive of Florida, LLC

CourtDistrict Court, M.D. Florida
DecidedMarch 17, 2023
Docket8:22-cv-00866
StatusUnknown

This text of Cohen v. Key Automotive of Florida, LLC (Cohen v. Key Automotive of Florida, LLC) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cohen v. Key Automotive of Florida, LLC, (M.D. Fla. 2023).

Opinion

UMNIIDTEDDL ES TDAISTTERS IDCITS TORFI FCLTO CROIDURAT TAMPA DIVISION

HADARI COHEN,

Plaintiff,

v. CASE NO. 8:22-cv-866-SDM-TGW

KEY SAFETY SYSTEMS, INC., and KEY AUTOMOTIVE OF FLORIDA, LLC,

Defendants. _____________________________________/

ORDER

Hadari Cohen, the personal representative of the Florida-probated estate of Shirley Cohen, sues (Doc. 1-1) Key Safety Systems, Inc. (operating as Joyson Safety Systems) and Key Automotive of Florida, LLC. In the complaint, Hadari alleges that a defective airbag inflator (designed and manufactured in Florida by the defend- ants and installed in Shirley’s car) caused Shirley’s death after an otherwise quotidian fender-bender in Jerusalem, Israel. The complaint asserts against each defendant a claim for negligence, wrongful death, and strict product liability. Invoking diversity jurisdiction, the defendants remove. (Doc. 1) Because the automobile accident “that forms th[e] basis of this [action]” reportedly “has no con- nection to the United States,” the defendants move (Doc. 33) to dismiss for forum non conveniens. Hadari responds (Doc. 41) and argues, among other things, that the ac- tion must continue in the United States because Israel, which statutorily eliminated any cause of action “for motor vehicle products liability cases,” is not an “available alternative forum.” With leave, the defendants reply (Doc. 46). BACKGROUND1 In May 2020, Shirley Cohen — driving her 2011 Alfa Romeo on the streets of

Jerusalem, Israel — rear-ended another car. (Doc. 1-1 at 5) Although causing little damage to either vehicle, the crash caused the Alfa’s internal computer to trigger both the driver-side airbag (embedded in the steering wheel) and the passenger-side airbag. (Doc. 1-1 at 2 & 5) Each of the Alfa’s several “airbag modules” — manufactured and sold to Alfa

by Joyson Safety Systems — relies on several component parts to achieve near in- stantaneous inflation upon impact. Each airbag includes a “Key Automotive ADI-D inflator” — a small device that catalyzes a chemical reaction upon direction by an airbag sensor. (Doc. 1-1 at 4) This chemical reaction creates the gas that inflates the airbag. Key Automotive of Florida allegedly manufactured the ADI-D inflator in-

stalled in the Alfa’s driver-side airbag. (Doc. 1-1 at 4) The ADI-D inflator “is a pyrotechnic two-stage inflator.” (Doc. 1-1 at 4) That is, the inflator creates the necessary gas by igniting a chemical compound, and the inflator contains two compounds that inflate the airbag to different levels based on a crash’s severity. Stage 1, triggered by low-speed crashes, burns the compound

1 The complaint (Doc. 1-1) asserts the following facts, which are presumed true in resolving a motion to dismiss. 5-aminotetrazole (5-AT); stage 2, triggered by high-speed crashes, burns the com- pound nitroguanidine. (Doc. 1-1 at 4) Because 5-AT “readily absorb[s] moisture from the environment,” “the [ADI- D] inflator housing is designed to be hermetically sealed.” (Doc. 1-1 at 6) In the

Alfa’s driver-side airbag, however, a defect in the inflator’s manufacture or design caused the seal to fail and allowed the 5-AT to absorb moisture, which significantly increased the 5-AT’s “burn rate.” (Doc. 1-1 at 7) Consequently, when the driver- side inflator ignited, the 5-AT burned much faster than anticipated and caused “ex- cessive internal pressures” that detached the airbag module from the steering wheel,

ruptured the inflator’s metal housing, and launched pieces of the ruptured housing — now shrapnel — throughout the vehicle. (Doc. 1-1 at 5–6) Several pieces of shrapnel struck Shirley in the head and upper body. (Doc. 1-1 at 6) As a result, Shirley suffered several injuries including “frontal skull fracture[] with penetration of bone fragments into the anterior brain, scattered cere-

bral bleeding, tonsillar herniation, ventricular compression, cerebral oedema, and left elbow fracture.” (Doc. 1-1 at 6) After a week on mechanical ventilation, Shirley died from these injuries. (Doc. 1-1 at 6) Although Shirley lived in Israel, her sister, Hadari Cohen, resides in Florida. In February 2022, Hadari petitioned (Doc. 33-1) a Florida court in Polk County to

administer Shirley’s estate. The petition asserts that venue is proper in Polk County because Shirley “had a debtor who resides in this county at the time of [her] death.” After the probate court appointed her as the personal representative of Shirley’s estate, Hadari sued (Doc. 1-1) Key Automotive and Joyson Safety Systems. Alleging that the defendants designed, manufactured, inspected, tested, and distributed the de- fective inflator module “in and from [their] Lakeland, Florida facilities,” the com- plaint asserts a claim against each defendant for (1) negligence, (2) failure to warn,

(3) wrongful death, and (4) strict product liability. The complaint asserts that each defendant is liable for the inflator’s allegedly defective design and asserts that Key Automotive is liable for the inflator’s allegedly defective manufacture. The defendants remove (Doc. 1) the action. Arguing that the action should continue in Israel, the defendants move (Doc. 33) to dismiss for forum non conveniens.

In response (Doc. 41) Hadari argues that Israel is not an “available alternative fo- rum” because an Israeli court would exercise no jurisdiction over this action. Also, Hadari argues that the defendants fail to demonstrate that the public and private fac- tors outweigh the substantial deference owed to an American plaintiff’s decision to sue in an American court. With leave, the defendants reply (Doc. 46).

DISCUSSION Moving (Doc. 33 at 1) to dismiss, the defendants insist that this action “is text- book forum shopping” and that “[t]he motor vehicle crash that forms th[e] basis of this [action] has no connection to the United States — it occurred over 6,000 miles away in Jerusalem.” Urging that this action should continue in Israel, the defend-

ants note (1) that Shirley “has no ties to the United States”; (2) that Shirley’s mother, the sole beneficiary Shirley’s estate, “lives in Israel”; (3) that Shirley’s Alfa “and all documentary evidence related to the accident . . . are located in Israel”; and (4) that “[e]very percipient witness, bystander, first responder, investigator, and [doctor] is in Israel.” Finally, the defendants assert that “Israel has a sophisticated judiciary and well-established statutory scheme” to remedy injury or death in a traffic accident. In response, Hadari first argues that Israel cannot justify dismissal for forum

non conveniens because “Israel lacks a private cause of action for motor vehicle prod- ucts liability cases.” (Doc. 41 at 4) Because Israeli law bars each claim, Hadari con- tinues, this action cannot resume in Israel and, consequently, the action must con- tinue in the United States. Also, Hadari argues that, as the personal representative of Shirley’s estate, Hadari — an American permanent resident and now citizen — is the

“real party in interest.” Hadari continues that, as an American plaintiff, her decision to sue in Florida warrants substantial deference.2 (Doc. 41 at 6) Hadari concludes that evidence of the inflator’s design and manufacture exists at the defendants’ “cor- porate and manufacturing facilities . . . located in Lakeland” and that the defendants fail to demonstrate that the evidence in Israel outweighs the deference afforded to

Hadari’s decision to sue in her home forum. Under Leon v. Million Air, Inc., 251 F.3d 1305, 1310–11 (11th Cir. 2001), a de- fendant moving to dismiss for forum non conveniens “must demonstrate [] (1) [that] an adequate alternative forum is available, (2) [that] the public and private factors weigh in favor of dismissal, and (3) [that] the plaintiff can reinstate his suit in the alternative

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