Doyle v. Combined Systems Inc

District Court, N.D. Texas·Decided October 30, 2023·No. 3:22-cv-01536·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

VINCENT DOYLE, BRANDON SAENZ, DAVID MCKEE, RANDI ROGERS, and TASIA WILLIAMS,

Plaintiffs,

Civil Action No. 3:22-CV-01536-K v.

COMBINED SYSTEMS, INC. and PENN ARMS,

Defendants.

MEMORANDUM OPINION AND ORDER

Before the Court are Plaintiffs Vincent Doyle, Brandon Saenz, David McKee, Randi Rogers, and Tasia Williams’s Motion for Leave to File Third Amended Com- plaint (the “Motion for Leave”), Doc. No. 43, and Plaintiffs’ Supplemental Brief in Support of Plaintiffs’ Motion for Leave to File Third Amended Complaint. Doc. No. 45. Upon consideration of the same, the Court GRANTS the Motion for Leave in part and DENIES it in part. Plaintiffs propose only negligible changes to their strict liability marketing defect and negligent and false marketing (negligent failure to warn) claims, which the Court already dismissed. None of those changes is responsive to the Court’s order of dismissal, so the Court DISMISSES those claims with prejudice. Plaintiffs propose more extensive changes to their remaining claims, and Defendants Combined Systems, Inc. and Penn Arms do not oppose amendment of those claims. Without expressing an opinion on their merits, the Court will permit their amendment as proposed.

I. BACKGROUND Plaintiffs allegedly suffered injuries when police officers shot them using rubber bullets and launchers sold by Defendants. Doc. No. 43-1 ¶¶ 21–37. Plaintiffs previ- ously sought to hold Defendants liable for the injuries under the Texas Deceptive Trade Practices Act (the “DTPA”) and under strict liability marketing defect, negligent failure to warn, and implied warranty of fitness theories. Doc. No. 14 ¶¶ 43–63.

On September 11, 2023, the Court issued a thirty-five page memorandum opin- ion and order dismissing Plaintiffs’ claims in their entirety without prejudice. Doc. No. 40. The Court first found that the Protection of Lawful Commerce in Arms Act (“PLCAA”) barred Plaintiffs’ strict liability marketing defect and negligent failure to

warn claims. Pub. L. No. 109-92, 119 Stat. 2095 (2005) (codified at 15 U.S.C. §§ 7901–7903); Doc. No. 40 at 19. The Court also found that Plaintiffs’ warranty and DTPA claims failed on the merits. In the interest of providing Plaintiffs guidance if they sought to amend their

claims, the Court provided additional analysis. Doc. No. 40 at 27. The Court ex- plained that “Plaintiffs’ strict liability marketing defect claim, though barred by the PLCAA, is otherwise adequately pled.” Id. at 30. The Court came to a different con- clusion with respect to Plaintiffs’ negligent failure to warm claim, dismissing the claim as “barred by the PLCAA” and for “failure to plausibly allege duty or causation.” Id. at 31. As the Court observed, Plaintiffs confusedly alleged that Defendants breached a duty to warn the general public about the dangers of Defendants’ products and then

argued in their briefing that the duty was to warn the police officers who shot Plaintiffs. Id. at 30. The Court found that Plaintiffs had not established that any duty ran spe- cifically to them regardless of the theory of duty advanced. Id. Assuming to the con- trary that Plaintiffs’ theory of a duty running to the general public was viable, the Court also expressly found that Plaintiffs had not plausibly alleged how Defendants’ pur-

ported breach of a duty to warn the general public about their products caused Plain- tiffs’ harm. Id. at 31. The Court noted that Plaintiffs apparently had no choice in the use of Defendants products against them. Id. Plaintiffs subsequently submitted their pending Motion for Leave to file a third

amended pleading. Doc. No. 43. Plaintiffs propose a number of changes to the war- ranty and DTPA claims the Court dismissed. Doc. No. 43-2 ¶¶ 53–64. Although Plaintiffs also seek to reassert their strict liability marketing defect and negligent failure to warn claims, Plaintiffs do not propose to amend any of the allegations supporting

the strict liability claim, and Plaintiffs’ sole proposed amendment to their negligent failure to warn claim is the allegation that the duty to warn Defendants purportedly owed to the general public is a duty “to warn of and make safe the dangers created by their products.” Id. ¶¶ 43–52. Concerned that Plaintiffs had not seriously attempted to remedy the issues the

Court identified with Plaintiffs’ strict liability marketing defect and negligent failure to warn claims, the Court ordered Plaintiffs to file a supplemental brief explaining why their proposed allegations state a claim under applicable law, including the Court’s

dismissal order. Doc. No. 44 at 2. The Court warned Plaintiffs that it was inclined deny them leave to amend their strict liability and negligent failure to warn claims and to dismiss those claims with prejudice. Id. at 1–2. Plaintiffs filed a supplemental brief in response. Doc. No. 45.

II. DISCUSSION While the Court appreciates the helpful clarification of Plaintiffs’ thinking set forth in their supplemental briefing, the Court remains convinced that the Plaintiffs’ proposed amendments are impermissible. In its dismissal order, the Court unequivo- cally stated that the PLCAA bars Plaintiffs’ strict liability marketing defect and negli- gent failure to warn claims. Doc. No. 40 at 30–31. Plaintiffs ignore this holding with

respect to their negligent failure to warn claim, suggesting that the Court relied solely on deficiencies in the merits of Plaintiffs’ pleading to dismiss the claim. Doc. No. 45 at 2. Plaintiffs pay lip service to the Court’s holding with respect to their strict liability marketing defect claim, contending that they did not need to amend the claim because

the Court stated that, “though barred by the PLCAA, [the claim] is otherwise ade- quately pled.” Id. That is not a credible interpretation of the Court’s order. Plaintiffs wisely stop short of suggesting that their proposed allegations, which are unchanged or nearly unchanged from the ones the Court considered when it dismissed their claims, can survive the application of the PLCAA. Plaintiffs also do not contend that they can amend their allegations to bring them within exceptions to the PLCAA.

The Court finds Plaintiffs’ attack on its analysis of the merits of Plaintiffs’ neg- ligent failure to warn claim similarly unpersuasive. Plaintiffs candidly admit that they “did not amend [the claim] significantly because they believe they adequately pled” the claim. Id. Attempting to supply the valid duty to warn the Court found missing in Plain-

tiffs’ nearly-identical second amended pleading, Plaintiffs contend in their supple- mental brief that Defendants had a duty to warn the general public about their prod- ucts through their police officer customers. Id. at 2–3. According to Plaintiffs, this duty arises from Alm v. Alcoa, 717 S.W.2d 588, 591 (Tex. 1986). Setting aside the fact

that Plaintiffs have never pled and never filed a proposed complaint pleading that De- fendants were obliged to warn the general public about their products through inter- mediaries, the Court disagrees that Alcoa recognizes a duty compelling Defendants to warn the general public about their products. The question before the court in Alcoa

was whether the defendant had a “duty to warn consumers,” and the court answered that the defendant did, but the defendant might be able to discharge the duty by warn- ing downstream manufacturers instead. Id. at 589, 592. Neither Plaintiffs nor the public writ large are “consumers”—or even users—of Defendants products.

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