Encompass Insurance Company v. Norcold Inc

District Court, W.D. Washington·Decided June 2, 2025·No. 2:23-cv-00231·Unknown

Opinion

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3 4 5 UNITED STATES DISTRICT COURT AT SEATTLE 7 ENCOMPASS INSURANCE COMPANY, CASE NO. 2:23-cv-231 8 Plaintiff, ORDER 9 v. 10 NORCOLD INC., 11 Defendant. 12 14 Intervention Plaintiff, 15 v. 17 Intervention Defendant. 18

19 1. INTRODUCTION 20 Subrogation-Plaintiff Encompass Insurance Company (“Encompass”) and 21 Intervention-Plaintiff Essentia Insurance Company (“Essentia”) bring this product- 22 liability suit against Defendant Norcold, Inc. (“Norcold”), alleging that a Norcold 23 refrigerator caused a fire that destroyed their insureds’ garage, vehicles, and other 1 property. Trial is set to begin on September 8, 2025. This matter comes before the 2 Court on the parties’ motions in limine. Dkt. Nos. 72, 74. Having reviewed the

3 motions, the briefing, the record, and the law, and having heard oral argument, see 4 Dkt. No. 87, the Court, being fully informed, ORDERS as follows. 5 2. LEGAL STANDARD 6 “A motion in limine is a procedural mechanism to limit in advance [of trial] 7 testimony or evidence in a particular area.” United States v. Heller, 551 F.3d 1108, 8 1111 (9th Cir. 2009). Motions in limine must identify the specific evidence sought to

9 be excluded and detail the reasoning for inadmissibility. United States v. Lewis, 493 10 F. Supp. 3d 858, 861 (C.D. Cal. 2020). A motion devoid of specificity or merely 11 reminding the court to follow established rules will generally be denied. See id. 12 Trial courts need no reminder of their fundamental duty to enforce the federal rules 13 during trial—that much is self-evident and requires no motion to secure. 14 Trial courts possess broad discretion when ruling on motions in limine, Heller, 551 F.3d at 1111, though such decisions are not binding and may be reconsidered at 15 trial, Ohler v. United States, 529 U.S. 753, 758 n.3 (2000). Thus, denial of a motion in 16 limine does not guarantee admission of contested evidence, but merely indicates that 17 without trial context, the court will not order exclusion. See id. In other words, denials 18 are without prejudice. And if the court grants a motion in limine, it may still revisit its 19 earlier ruling based on the events at trial. 20 21 3. STIPULATED MOTIONS 22 The Court GRANTS the stipulated motions below: 23 1 MOTION 1: “Exclusion of Statements and Evidence About Norcold’s Plant 2 Closures.” See Dkt. No. 74 at 3.

3 MOTION 2: “Exclusion of Statements and Evidence About Norcold’s 4 Insurance.” See Dkt. No. 74 at 3. 5 MOTION 3: “Exclusion of Statements and Evidence of the Size, Revenue, 6 Financial Net Worth, or Wealth of the Parties.” See Dkt. No. 74 at 4. 7 MOTION 4: “Exclusion of Statements and Evidence Relating To Punitive 8 Damages.” See Dkt. No. 74 at 4.

9 MOTION 5: “Exclusion of ‘Golden Rule’ Arguments.” See Dkt. No. 74 at 4. 10 MOTION 6: “Exclusion of Statements that Norcold Can Better Afford to Pay 11 Damages or Expenses Incurred by Plaintiffs.” See Dkt. No. 74 at 4. 12 MOTION 7: “Exclusion of Evidence of Settlement Discussions.” See Dkt. No. 13 74 at 4. 14 MOTION 8: “Preclusion of Statements About Witnesses Not Called.” See 15 Dkt. No. 74 at 5.

16 MOTION 9: “Preclusion of Statements About the Probable Testimony of 17 Absent Witnesses.” See Dkt. No. 74 at 5. 18 MOTION 10: “Preclusion of Attempts to Have Any Party Stipulate to Facts 19 or Documents or to Agree to Produce Documents.” See Dkt. No. 74 at 5. 20 MOTION 11: “Preclusion of Statements About Discovery Disputes.” See Dkt. 21 No. 74 at 5.

22 MOTION 12: “Preclusion of Statements About Motions in Limine.” See Dkt. 23 No. 74 at 6. 1 MOTION 13: “Preclusion of Statements About Litigation Strategy.” See Dkt. 2 No. 74 at 6.

3 4. PLAINTIFFS’ CONTESTED MOTIONS 4 The Court RULES as follows on Plaintiffs’ contested motions in limine. 5 MOTION A: Plaintiffs move to exclude any evidence “refuting the value or 6 reasonableness of Plaintiffs’ damages” on the grounds that Norcold has not 7 disclosed any testimony on this issue. Dkt. No. 72 at 2–3. Plaintiffs fail to identify 8 what type of damages they claim requires expert testimony to challenge. Even more 9 to the point, Plaintiffs cite no authority establishing that expert testimony is 10 generally required to contest the reasonableness of damages. To the contrary, lay 11 witness testimony will often suffice to establish or challenge damages. See Salisbury 12 v. City of Seattle, 522 P.3d 1019, 1025 (Wash. Ct. App. 2023) (“[T]here is no reason 13 lay witnesses may not testify to their sensory perceptions, the weight of the 14 testimony to be determined by the trier of fact” to establish future damages). This 15 motion is DENIED. 16 MOTION B: Plaintiffs move to exclude any evidence of “Plaintiffs failing to 17 mitigate their damages” on the grounds that “none of the experts or lay witnesses 18 disclosed by Defendant presented any opinions regarding Plaintiffs failing to 19 mitigate their damages.” Dkt. No. 72 at 3–4. The Court will adhere to the Federal 20 Rules governing expert witness disclosures and opinion, as well as the rules 21 controlling opinion testimony by lay witnesses. This motion is DENIED. 22 23 1 MOTION C: Plaintiffs move to exclude any evidence that “[n]o safer, 2 alternative design for the subject Norcold refrigerator existed at the time the

3 refrigerator was manufactured that was technologically and economically feasible” 4 on the grounds that “[n]one of the experts disclosed by Defendant presented any 5 opinions regarding any alternative designs for the Norcold refrigerator.” Dkt. No. 72 6 at 4. Norcold counters that “[t]he fact Norcold’s experts did not provide any opinion 7 as to potential alternative designs does not preclude Norcold itself from testifying 8 regarding its own product.” Dkt. No. 78 at 4. Norcold is right. This motion is

10 MOTION D: Plaintiffs move to “admit other prior similar incidents identified 11 by Norcold in discovery.” Dkt. No. 72 at 4. Specifically, they seek to admit 12 “investigations and photographs” from twenty-three product-liability claims against 13 Norcold, and to elicit expert testimony about these claims. See Dkt. No. 79 at 8–19. 14 They also seek to exclude “any testimony that claims listed by Defendant in 15 response to Interrogatory No. 11 and contents of claim files produced by Defendant

16 in response to Interrogatory No. 14 do not involve the same Norcold Refrigerator as 17 is at issue in this case.” Dkt. No. 72 at 4. 18 “A showing of substantial similarity is required when a plaintiff attempts to 19 introduce evidence of other accidents as direct proof of negligence, a design defect, 20 or notice of the defect.” Cooper v. Firestone Tire & Rubber Co., 945 F.2d 1103, 1105 21 (9th Cir. 1991). This rule “rests on the concern that evidence of dissimilar accidents

22 lacks the relevance required for admissibility under [Fed. R. Evid.] 401 and 402.” 23 Id. “Evidence proffered to illustrate the existence of a dangerous condition 1 necessitates a high degree of similarity because it weighs directly on the ultimate 2 issue to be decided by the jury.” Wheeler v. John Deere Co., 862 F.2d 1404, 1407

3 (10th Cir. 1988). “The burden is on the proponent of the evidence to demonstrate 4 substantial similarity.” Smith v. Beech Aircraft Corp., Case No. 97-17135, 1999 WL 5 274515, at *1 (9th Cir. April 29, 1999).

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