Dietrick v. Barnett Outdoors, LLC

CourtDistrict Court, M.D. Pennsylvania
DecidedSeptember 30, 2021
Docket3:20-cv-02157
StatusUnknown

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

Bluebook
Dietrick v. Barnett Outdoors, LLC, (M.D. Pa. 2021).

Opinion

THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA RONALD DIETRICK AND CATHERINE DIETRICK, Plaintiffs, : 3:20-CV-2157 V. : (JUDGE MARIANI) BARNETT OUTDOORS, LLC, Defendant. MEMORANDUM OPINION I. INTRODUCTION On October 28, 2020, plaintiffs Ronald Dietrick and Catherine Dietrick, (“Plaintiffs’), filed a complaint, (the “Complaint’), in the Court of Common Pleas of Luzerne County. (Doc. 1-1). On November 18, 2020, defendant Barnett Outdoors, LLC, (“Defendant” or “Barnett Outdoors”), filed a Notice of Removal to remove the action from state court to this Court on the basis of diversity jurisdiction pursuant to 28 U.S.C. § 1332. (Doc. 1-4). Pennsylvania substantive law therefore applies to Plaintiffs’ state law claims. Erie R.R. Co.

v. Tompkins, 304 U.S. 64, 91-92 (1938). Presently before the Court is Defendant's Motion to Dismiss two counts of Plaintiffs’ Complaint for failure to state a claim upon which relief may be granted. (Doc. 3). For the reasons set forth below, the Court will deny Defendant's Motion to Dismiss as to Plaintiffs’ claim for breach of warranty (Count Ill) and will grant the Defendant's Motion as to Plaintiffs’ claim for punitive damages (Count IV).

Il. PROCEDURAL HISTORY AND FACTUAL ALLEGATIONS Defendant Barnett Outdoors, LLC operates a limited liability company with its principal place of business in Tarpon Springs, Florida. (Doc. 1-1 at { 2). Defendant's business focuses on “designing, manufacturing, selling, and distributing crossbows.” (Id. at 7 4). On or about November 7, 2018, while in possession of a Barnett crossbow “purchased by/for Plaintiff, Ronald Dietrick,” Mr. Dietrick was injured when the bowstring of the crossbow he was operating “was released and hit his left hand,” causing injury to his left thumb. (Id. at Plaintiffs allege that this injury was caused by a defect in the crossbow

as there was “no adequate thumb guard or protector that would prevent the injury above, nor were there adequate warnings of danger or instructions for safe use of the product.” (Id. at J 13). Plaintiffs raise five separate claims concerning Mr. Dietrick’s injuries, including claims for strict products liability (Count 1), negligence (Count II), breach of warranties (Count Ill), punitive damages (Count IV), and loss of consortium (Count V). Of these claims, the main basis for liability revolves around the Defendant's inability to warn consumers of the dangers of its products and to equip the crossbow used by Mr. Dietrick with a protective guard to avoid injury to his thumb. In response to Plaintiffs’ claims, Defendant filed a Motion to Dismiss arguing that Plaintiffs fail to sufficiently allege a claim for breach of express warranty for Count Ill and that Pennsylvania law does not recognize a cause of action for punitive damages for Count IV. (Doc. 5 at 2).

Ill. STANDARD OF REVIEW A complaint must be dismissed under Federal Rule of Civil Procedure 12(b)(6) if it does not allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 505 U.S. 544, 570 (2007). The plaintiff must assert “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). “While a complaint attached by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations, a plaintiff's obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555 (internal citations, alterations, and quotation marks omitted). In other words, “[flactual allegations must be enough to raise a right to relief above the speculative level.” Covington v. Int'l Ass’n of Approved Basketball Offs., 710 F.3d 114, 118 (3d Cir. 2013) (internal citations and question marks omitted). A court “take|s] as true all the factual allegations in the Complaint and the reasonable inferences that can be drawn from those facts, but ... disregard[s] legal conclusions and threadbare recitals of the elements of a cause of action, supported by mere conclusory statements.” Ethypharm S.A. France v. Abbott Labs., 707 F.3d 223, 231 n. 14 (3d Cir. 2013) (internal citation and quotation marks omitted). Thus “the presumption of

truth attaches only to those allegations for which there is sufficient ‘factual matter’ to render them ‘plausible on [their] face.” Schuchardt v. President of the United States, 839 F.3d 336, 347 (3d Cir. 2016) (alterations in original) (quoting /qbal, 556 U.S. at 679). “Conclusory assertations of fact and legal conclusions are not entitled to the same presumption.” /d. Twombly and Iqbal require [a district court] to take the following three steps to determine the sufficiency of a complaint: First, the court must take note of the elements a plaintiff must plead to state a claim. Second, the court should identify allegations that, because they are no more than conclusions, are not entitled to the assumption of truth. Finally, where there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement for relief. Connelly v. Steel Valley Sch. Dist., 706 F.3d 209, 212 (3d Cir. 2013). “Although the plausibility standard ‘does not impose a probability requirement,’ it does require a pleading to show ‘more than a sheer probability that a defendant has acted unlawfully.” Connelly v. Lane Constr. Corp., 809 F.3d 780, 786 (3d Cir. 2016) (internal citation omitted) (first quoting Twombly, 550 U.S. at 556; then quoting /gbal/, 556 U.S. at 678). “The plausibility determination is ‘a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” /d. at 786-87 (quoting /qbal, 556 U.S. at 679). The Court, however, does not “require heightened fact pleading of specifics, but only enough facts to state a claim to relief that is plausible on its face” and “nudge [a plaintiffs] claims across the line from conceivable to plausible.” Twombly, 550 U.S. at 547; see also Iqbal, 556 U.S. at 680 (citing Twombly) (finding that respondent had failed to plead sufficient facts to state a claim for purposeful and unlawful discrimination as

“respondent's complaint ha[d] not ‘nuaged [his] claims’ of invidious discrimination ‘across the line from conceivable to plausible”). IV. ANALYSIS Defendant's Motion to Dismiss argues that Plaintiffs fail to sufficiently allege a claim

for breach of express warranty for Count Ill and that Pennsylvania law does not recognize causes of action for punitive damages for Count IV. (Doc. 5 at 2). These two claims will be addressed in turn. 1. Motion to Dismiss Plaintiffs’ Breach of Express Warranty Claim To sustain a claim for breach of express warranty, a plaintiff must generally establish: “(1) defendants breached or failed to meet its warranty promise, (2) the breach

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Bluebook (online)
Dietrick v. Barnett Outdoors, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dietrick-v-barnett-outdoors-llc-pamd-2021.