In Re Ford Motor Co. Speed Control Deactivation Switch Products Liability Litigation

793 F. Supp. 2d 1018, 2010 U.S. Dist. LEXIS 143338, 2010 WL 6815775
CourtDistrict Court, E.D. Michigan
DecidedNovember 23, 2010
DocketMDL Docket No. 05-1718. Case No. 09-14778
StatusPublished
Cited by1 cases

This text of 793 F. Supp. 2d 1018 (In Re Ford Motor Co. Speed Control Deactivation Switch Products Liability Litigation) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Ford Motor Co. Speed Control Deactivation Switch Products Liability Litigation, 793 F. Supp. 2d 1018, 2010 U.S. Dist. LEXIS 143338, 2010 WL 6815775 (E.D. Mich. 2010).

Opinion

ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

BERNARD A. FRIEDMAN, District Judge.

I.Introduction

This matter is before the Court on Defendant Ford Motor Company’s (“Ford”) motion for judgment as a matter of law pursuant to Fed.R.Civ.P. 56(c). Ford contends that it is beyond dispute that the subject vehicle in this underlying case was sold to its first consumer purchaser more than twelve years before the fire in this incident case occurred and, therefore, Plaintiffs claims are barred by Florida’s statute of repose, § 95.031(2)(b), Fla. Stat.

In response, Plaintiff, Stasha Northcutt (“Northcutt”) argues that Ford’s motion for summary judgment must be denied because the active knowledge and concealment exception to the Florida statute of repose applies in this case, thereby causing the statutory twelve year period to toll and rendering Plaintiffs lawsuit against Ford timely filed.

II. Background

Plaintiff claims that her product liability claim arises from a fire that occurred on March 23, 2009 due to a defective speed control deactivation switch in a 1997 Ford Expedition (“Exhibition”) owned by her tenant, Kevin Abraham. The fire resulted in damage to her home and, Plaintiff contends, lost rental income. She states in her response that there is no question that the defective speed control deactivation switch in the Exhibition was the cause of the fire.

The Exhibition was sold to its first consumer purchaser in 1996. Abraham acquired the Exhibition five or six years prior to the fire from a private owner, and used it for personal use. Abraham did not receive a recall or other notice relating to the speed control deactivation switch in the Exhibition, and did not experience any problems with the speed control deactivation switch prior to the fire.

Plaintiff contends that she can cite to evidence clearly demonstrating Defendant’s knowledge of the defective switch as of 1999, and that she is further able to show that Defendant had multiple opportunities to notify the public and the owner of the Exhibition prior to the 2005 recall of the Exhibition (“2005 recall”).

III. Standard of Review

Summary judgment is proper where there is no genuine issue of material fact, and the moving party is entitled to judgment as a matter of law. In considering a motion for summary judgment, the Court will construe all facts in a light most favorable to the non-moving party. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). There are no genuine issues of *1020 material fact when “the record taken as a whole could not lead a rational trier of fact to find for the nonmoving party.” Id. If the movant carries its burden of showing an absence of evidence to support a claim, then the nonmovant must demonstrate by affidavits, depositions, answers to interrogatories, and admissions that a genuine issue of material fact exists. Celotex Corp. v. Catrett, 477 U.S. 317, 324-325, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986).

IV. Analysis

Plaintiffs complaint asserts three claims: negligence, strict product liability-product defect, and strict product liability-failure to warn. Each claim depends on the existence of a defect in the Exhibition, which allegedly caused the 2009 fire.

Plaintiff contends that in 1999, Defendant knew about the defective nature of the Texas Instruments speed control deactivation switch used in its vehicles, including the 1997 Exhibition. Specifically, Plaintiff states, Defendant knew about the propensity of the switch to overheat and thereby ignite a fire under the hood of a Ford vehicle. Plaintiff argues that Ford’s discovery of the switch defect led to Ford’s recall of a number of vehicles containing the defective switch, but Ford failed to recall any 1997 Ford Exhibitions until September 2005. Plaintiff states that Ford actively concealed its knowledge of the defective switch from the owners of the 1997 Ford Exhibitions for six years. Accordingly, Plaintiff argues, the repose period in this case must be extended by six years, causing any claim accrued and filed before 2014 to be timely, and therefore, Defendant’s motion for summary judgment should be denied.

Florida’s statute of repose states the following:

(b) An action for products liability under s. 95.11(3) must be begun within the period prescribed in this chapter, with the period running from the date that the facts giving rise to the cause of action were discovered, or should have been discovered with the exercise of due diligence, rather than running from any other date prescribed elsewhere in s. 95.11(3), except as provided within this subsection. Under no circumstances may a claimant commence an action for products liability, including a wrongful death action or any other claim arising from personal injury or property damage caused by a product, to recover for harm allegedly caused by a product with an expected useful life of 10 years or less, if the harm was caused by exposure to or use of the product more than 12 years after delivery of the product to its first purchaser or lessee who was not engaged in the business of selling or leasing the product or of using the product as a component in the manufacture of another product.

§ 95.031(2)(b)Fla. Stat.

The exception to which Plaintiff cites states:

(d) The repose period prescribed within paragraph (b) is tolled for any period during which the manufacturer through its officers, directors, partners, or managing agents had actual knowledge that the product was defective in the manner alleged by the claimant and took affirmative steps to conceal the defect. Any claim of concealment under this section shall be made with specificity and must be based upon substantial factual and legal support. Maintaining the confidentiality of trade secrets does not constitute concealment under this section.

§ 95.031(2)(d)Fla. Stat.

Defendant argues that Plaintiff has failed to meet her statutory burden of demonstrating that the “manufacturer, through its officers, directors, partner, or managing agents had actual knowledge *1021 that the product was defective ... and took affirmative steps to conceal the defect.” Further, Defendant argues that Plaintiff has failed to make her “claim of concealment ... with specificity” and failed to base it “upon substantial factual and legal support.” Id. Accordingly, Defendant argues, the exception to the Florida statute of repose is inapplicable, and summary judgment must be granted.

Plaintiff’s response to Defendant’s motion is based on her argument that Defendant’s active concealment of the defect caused the repose period to toll.

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Bluebook (online)
793 F. Supp. 2d 1018, 2010 U.S. Dist. LEXIS 143338, 2010 WL 6815775, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-ford-motor-co-speed-control-deactivation-switch-products-liability-mied-2010.