International Insurance Company of Hannover SE as Subrogee to Association of United States Postal Lessors v. Wal-Mart Stores, Inc., Wal-Mart Stores Texas, L.P., and Wal-Mart Associates, Inc.

CourtCourt of Appeals of Texas
DecidedAugust 2, 2018
Docket13-17-00349-CV
StatusPublished

This text of International Insurance Company of Hannover SE as Subrogee to Association of United States Postal Lessors v. Wal-Mart Stores, Inc., Wal-Mart Stores Texas, L.P., and Wal-Mart Associates, Inc. (International Insurance Company of Hannover SE as Subrogee to Association of United States Postal Lessors v. Wal-Mart Stores, Inc., Wal-Mart Stores Texas, L.P., and Wal-Mart Associates, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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International Insurance Company of Hannover SE as Subrogee to Association of United States Postal Lessors v. Wal-Mart Stores, Inc., Wal-Mart Stores Texas, L.P., and Wal-Mart Associates, Inc., (Tex. Ct. App. 2018).

Opinion

NUMBER 13-17-00349-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI - EDINBURG

INTERNATIONAL INSURANCE COMPANY OF HANNOVER SE AS SUBROGEE TO ASSOCIATION OF UNITED STATES POSTAL LESSORS, Appellant,

v.

WAL-MART STORES, INC., WAL-MART STORES TEXAS, L.P., AND WAL-MART ASSOCIATES, INC., Appellees.

On appeal from the 105th District Court of Nueces County, Texas.

MEMORANDUM OPINION

Before Justices Contreras, Longoria and Hinojosa Memorandum Opinion by Justice Hinojosa

Appellant International Insurance Company of Hannover SE as subrogee to Association of United States Postal Lessors (Hannover) appeals a summary judgment

dismissing its products liability claims against Wal-Mart Stores, Inc., Wal-Mart Stores

Texas, LP, and Wal-Mart Associates, Inc. (Wal-Mart). By one issue, Hannover argues

that the trial court erred in granting Wal-Mart’s no-evidence motion for summary judgment

because it presented more than a scintilla of evidence that: (1) Wal-Mart sold a defective

space heater; and (2) established an exception to Wal-Mart’s statutory protection as an

innocent seller. We affirm.

I. BACKGROUND

A fire caused damage to a United States Post Office located in Corpus Christi,

Texas. Hannover, the insurer for the property, paid $1,675,388.31 for damages to the

post office. After an investigation revealed that a malfunctioning space heater might

have started the fire, Hannover filed a subrogation suit against Wal-Mart, 1 alleging

causes of action for products liability and negligence.

Wal-Mart filed a no-evidence motion for summary judgment, asserting that there

was no evidence it sold the heater. In the alternative, Wal-Mart maintained that it was

shielded from liability as an innocent seller pursuant to Texas Civil Practices and

Remedies Code section 82.003. See TEX. CIV. PRAC. & REM. CODE ANN. § 82.003 (West,

Westlaw through 2017 1st C.S.). Wal-Mart also argued that there was no evidence that

the heater was the proximate cause of the fire.

Hannover filed a response supported by the following evidence: the affidavit of

its expert Dennis Rasco; the deposition of postal employee Thelma Medina who

1 Hannover also sued Aloha Housewares, Inc., Forta Electronics Co., Staples Inc., and Staples the Office Superstore, LLC. They are not parties to this appeal. 2 purchased the heater; a research report prepared by Diversified Product Inspections, LLC

(DPI); recall notices from the United States Consumer Product Safety Commission

(CPSC); a Texas Secretary of State website print-out pertaining to Aloha Housewares,

Inc. (Aloha); and the affidavit of Katy Ohlsson.

In his affidavit, Rasco, an electrical engineer, opined that the heater caused the

post office fire. Rasco examined the heater and discovered that a contact arm of the

electrical component was bent and distorted. He concluded that the design of the heater

presented an unreasonable danger due to “[t]he failure of the electrical component” and

“[t]he CPSC recall instructing consumers to immediately stop using the recalled heater[.]”

Rasco did not offer any opinion concerning the identity of the heater, instead referencing

the conclusions of the DPI report.

DPI prepared a report comparing the damaged heater to an exemplar, which was

branded as a “FlowPro” heater. DPI “determined that each heater was manufactured

and/or distributed by the same company.” DPI, however, was unable to determine the

damaged heater’s model number, serial number, or date of manufacture “[d]ue to the lack

of product markings[.]” DPI stated that there was a CPSC product recall for heaters “with

an identical or nearly identical design as [the damaged heater.]” The DPI report labels

Aloha as a “manufacturer and/or distributor.” Attached to the report was a CPSC product

recall notice for FlowPro heaters. The recall notice referenced an unidentified Chinese

manufacturer. Also attached to the report was a document identifying Aloha as the

registrant of the trademark FlowPro. Hannover attached additional CPSC recall notices

identifying Aloha as the “Importer/Distributor” of heaters manufactured by an unidentified

3 Chinese company and sold at Wal-Mart stores.

In her deposition testimony, Medina testified that she could not remember where

or when she purchased the heater. In her affidavit, Ohlsson detailed her efforts on behalf

of Hannover to access records from the United States Postal Service under the Freedom

of Information Act.

Following a hearing, the trial court granted Wal-Mart’s no-evidence motion for

summary judgment. This appeal followed.

II. DISCUSSION

By its sole issue, Hannover argues that “more than a scintilla of evidence exists

that Wal-Mart is liable[.]”

A. Standard of Review

After adequate time for discovery, a party without presenting summary judgment

evidence may move for summary judgment on the ground that there is no evidence of

one or more essential elements of a claim or defense on which an adverse party would

have the burden of proof at trial. TEX. R. CIV. P. 166a(i). A motion for no-evidence

summary judgment is equivalent to a motion for pretrial directed verdict, and we apply the

same legal sufficiency standard on review. Nalle Plastics Fam. Ltd. P’ship v. Porter,

Rogers, Dahlman & Gordon, P.C., 406 S.W.3d 186, 199 (Tex. App.—Corpus Christi 2013,

pet. denied). Such a motion should be granted if there is no evidence of at least one

essential element of the claimant’s cause of action. Hamilton v. Wilson, 249 S.W.3d 425,

426 (Tex. 2008).

All that is required of the non-movant is to produce a scintilla of probative evidence

4 to raise a genuine issue of material fact on the challenged element. Forbes Inc. v.

Granada Biosciences, Inc., 124 S.W.3d 167, 172 (Tex. 2003). Less than a scintilla of

evidence exists when the evidence is so weak as to do no more than create a mere

surmise or suspicion of a fact. Id. More than a scintilla of evidence exists if it would

allow reasonable and fair-minded people to differ in their conclusions. Id. In

determining whether the non-movant has produced more than a scintilla of evidence, we

review the evidence in the light most favorable to the non-movant, crediting such evidence

if reasonable jurors could and disregarding contrary evidence unless reasonable jurors

could not. Nalle Plastics, 406 S.W.3d at 199.

B. Applicable Law

Chapter 82 of the Texas Civil Practice and Remedies Code was added by the

legislature to protect sellers from products liability suits unless they significantly and

intentionally participated in the design or production of the product. Manchester Tank &

Equip. Co. v. Engineered Controls Int’l, Inc., 311 S.W.3d 573, 575 (Tex. App.—Waco

2009, pet. denied). The purpose of the statute is to protect innocent sellers by assigning

responsibility for the burden of products-liability litigation to product manufacturers.

Petrol. Sols., Inc. v.

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Related

Forbes Inc. v. Granada Biosciences, Inc.
124 S.W.3d 167 (Texas Supreme Court, 2003)
General Motors Corp. v. Hudiburg Chevrolet, Inc.
199 S.W.3d 249 (Texas Supreme Court, 2006)
Hamilton v. Wilson
249 S.W.3d 425 (Texas Supreme Court, 2008)
In Re Atlas Tubular, L.P.
296 S.W.3d 363 (Court of Appeals of Texas, 2009)

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