Justice v. Safeway (USA), Inc.

District Court, E.D. Missouri·Decided December 30, 2024·No. 4:22-cv-00050·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

KYLE JUSTICE and ANNALEAH ) JUSTICE, ) ) Plaintiffs, ) ) v. ) No. 4:22-cv-00050-AGF ) BESTWAY (USA), INC., and RURAL ) KING HOLDINGS, LLP, ) ) Defendants, ) ) and ) ) BESTWAY (USA), INC., ) ) Third-Party Plaintiff, ) ) v. ) ) MARY FLAKE and PATRICK FLAKE, ) ) Third-Party Defendants, ) ) and ) ) RURAL KING HOLDINGS, LLP, ) ) Cross Claimant, ) ) v. ) ) MARY FLAKE and PATRICK FLAKE, ) ) Cross Defendants, ) ) and ) ) RURAL KING HOLDINGS, LLP, ) ) Third-Party Plaintiff, ) ) v. ) ) BESTWAY (HONG KONG) ) INTERNATIONAL LIMITED and ) BESTWAY INFLATABLES & ) MATERIALS CORPORATION, ) ) Third-Party Defendants. )

MEMORANDUM AND ORDER

This matter is before the Court on Third-party Defendants Bestway (Hong Kong) International Limited’s and Bestway Inflatables & Materials Corporation’s (collectively, the “Bestway Entities”) Motion to Exclude the expert reports, testimony, and opinions of Dr. Kevin A. Rider, PhD. ECF No. 119. Dr. Rider was designated as an expert witness by Third-party Defendants Mary and Patrick Flake. The Flakes filed a response (ECF No. 131), and the Bestway Entities filed a reply (ECF No. 145). This matter is now fully briefed and ripe for disposition. For the reasons set forth below, the Court will grant in part and deny in part the Bestway Entities’ Motion. Background This case involves claims raised by Plaintiffs Kyle and Annaleah Justice against Defendants Bestway USA and Rural King Holdings, Inc. under the Missouri Wrongful Death Statute, Mo. Rev. Stat. § 537.080. Plaintiffs’ claims arise from the drowning death of their minor daughter, E.M.J., in an above-ground pool on August 3, 2019. Plaintiffs filed their Complaint against Bestway USA and Rural King on January 18, 2022. ECF No. 5.

On March 10, 2022, Bestway USA filed a Third-party Complaint against Third- party Defendants, Mary and Patrick Flake, E.M.J.’s grandparents and the owners of the pool in which E.M.J. drowned. Bestway USA raises two claims against the Flakes: Count I for Premises Liability and Count II for Negligence. ECF No. 10. On August 25, 2023, Defendant Rural King filed a Third-party Complaint raising four total claims against the Bestway Entities: Count I – Negligence against Bestway

Hong Kong; Count II – Negligence against Bestway Inflatable and Materials Corporation; Count III – Strict Liability against Bestway Hong Kong; and Count IV – Strict Liability against Bestway I&M. ECF No. 76. Dr. Kevin Rider, PhD, is a human factors and engineering expert retained by Third-party Plaintiffs Mary and Patrick Flake. ECF No. 119-1 at 2. He was retained “to

determine if the subject pool was safe for its intended use, particularly as it relates to other expert opinions that have been provided regarding the same.” Id. Dr. Rider holds a PhD in industrial and operations engineering from the University of Michigan and master’s and bachelor’s degrees in industrial engineering from the University of Tennessee. Id. He has nearly thirty (30) years of experience in the fields of engineering

and human factors. He intends to offer the following opinions: 1. The Flakes and Justices complied with the warning of which they were aware – the ladder had been removed from the pool. 2. Based on [E.M.J.]’s demonstrated climbing abilities, the removal of the ladder should have provided an effective guard, which would have prevented this incident from occurring. 3. The published literature is consistent with the conclusion of Detective Doerr and others regarding how this incident occurred. 4. The nylon strap effectively created a wall that was approximately 37” high, 11 inches shorter than the 48” barrier requirement, defeating the performance criteria intended by standards. 5. The effective height of the subject pool wall failed to provide the safety intended by relevant standards and created an unreasonable risk of harm to toddlers, such as [E.M.J.]. Id. at 9. The Bestway Entities argue that Dr. Rider’s opinions should be excluded because they are not based on sufficient facts and data, are not the result of a reliable application of a methodology to the facts, and are speculative and unhelpful to the jury. Specifically, the Bestway Entities contend that Dr. Rider did not perform any of his own data collection or analysis, but rather accepted information and data provided to him by other experts in the case and opined on whether these other experts’ conclusions fit that data. The Bestway Entities argue that Dr. Rider’s failure to obtain data independently and to conduct his own testing render his conclusions inadmissible. The Bestway Entities rely on Missouri case law1 on the admissibility of expert opinion, but do not explain why this case law is applicable in this Court, which is governed by the Federal Rules of Evidence.

1 At one point in their brief, the Bestway Entities even describe a Missouri Court of Appeals case as an opinion from this Court. ECF No. 119 at 9 (citing to Hargan v. Sears, Roebuck and Co., 787 S.W.2d 766, 768 (Mo. Ct. App. 1990), but inaccurately representing it as a coming from E.D. Mo.). This case, like the other cited opinions from Missouri courts regarding Missouri rules of evidence, is inapplicable here. As to their argument that Dr. Rider did not reliably apply a methodology to the facts, the Bestway Entities present several related arguments. First, the Bestway Entities

assert that Dr. Rider failed to account for Mary Flake’s past experience babysitting and raising children in forming his conclusions about what dangers she was aware of regarding the pool. Second, the Bestway Entities also question the reliability of Dr. Rider’s opinion regarding what warnings the Flakes and the Justices were aware of given their testimony that they never read the pool’s warnings. Third, the Bestway Entities contend that Dr. Rider improperly relied on studies about the climbing abilities of three-

year-old children rather than crediting results from those studies regarding two-year-old children. The Bestway Entities argue that because E.M.J. was two at the time of her death, Dr. Rider cannot reliably compare her alleged abilities to those of three-year-olds included on such studies. The Bestway Entities arguments that Dr. Rider’s testimony will not be helpful to

the jury are a repeat of their previous arguments. They contend that Dr. Rider’s opinions “should be excluded because they are so fundamentally unsupported that they can offer no assistance to the jury.” ECF No. 119 at 14. The Bestway Entities then argue that Dr. Rider is not qualified to testify regarding industry design standards and therefore should be precluded from offering any opinions on those issues.

The Flakes provide a brief response to each of the Bestway Entities’ arguments. First, the Flakes argue that the issue of whether Dr. Rider’s conclusions are supported by sufficient facts or data is one of weight and not admissibility. The Flakes emphasize that Dr. Rider’s is not required to rely exclusively on data and information he personally gathered, and instead he must only rely on sufficient, competent evidence.

Second, the Flakes argue that Dr. Rider’s opinions are the result of a reliable application of a human factors methodology to the facts of this case. They state, without citation to the record, that he relied on peer-reviewed articles and published literature in the field of human factors analysis in forming his conclusions. The Flakes then state that Dr. Rider’s testimony should be admitted because it is relevant. Third, the Flakes argue that Dr. Rider’s opinions will be helpful to the jury

because “his expertise and insight into human behavior . . .

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Justice v. Safeway (USA), Inc., (E.D. Mo. 2024).

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