Liebick v. Samsung Electronics America, Inc.

CourtDistrict Court, E.D. California
DecidedAugust 1, 2025
Docket2:25-cv-01300
StatusUnknown

This text of Liebick v. Samsung Electronics America, Inc. (Liebick v. Samsung Electronics America, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Liebick v. Samsung Electronics America, Inc., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 FOR THE EASTERN DISTRICT OF CALIFORNIA 7 8 NEIL LIEBICK; SHARON CLARK, No. 2:25-cv-01300-DJC-DMC individually and as guardian ad litem 9 for JANE DOE 1, JANE DOE 2, and JOHN DOE; and JASON FRANKLIN, 10 ORDER GRANTING MOTION TO DISMISS Plaintiffs, 11 v. 12 SAMSUNG ELECTRONICS AMERICA, 13 INC.; and COSTCO WHOLESALE CORP., 14 Defendants. 15 16 Plaintiffs purchased an electric range manufactured by one Defendant and sold 17 by the other Defendant. After purchasing the range, Plaintiffs’ house tragically burned 18 down. Months later, after Plaintiffs received notice of a voluntary recall regarding the 19 electric range, they suspected the product caused the fire and filed suit for products 20 liability, negligence, and breach of warranty. Because they brought action in state 21 court, Plaintiffs completed a form complaint and attached just five sentences of factual 22 allegations. Defendants removed to federal court on the basis of diversity jurisdiction, 23 and they now jointly move to dismiss all claims, arguing that Plaintiffs fail to satisfy the 24 federal pleading standard. The Court agrees and therefore GRANTS Defendants’ 25 Motion to Dismiss (ECF No. 10) with leave to amend. 26 BACKGROUND 27 Neil Liebick, Jason Franklin, and Sharon Clark, individually and as guardian ad 28 litem for Jane Doe 1, Jane Doe 2, and John Doe, (collectively, “Plaintiffs”) purchased 1 an electric range that was manufactured by Samsung Electronics America, Inc. and 2 sold by Costco Wholesale Corp. (collectively, “Defendants”). (Notice of Removal at 3 15, ECF No. 1.) After Plaintiffs’ house burned down in January 2024, Plaintiffs learned 4 that their electric range was subject to a voluntary recall because the knobs could be 5 activated through accidental contact. (Id. at 16.) Plaintiff filed a form complaint (“the 6 Complaint”), bringing causes of action for strict liability, negligence, and breach of 7 warranty. (Id. at 15.) The only factual allegations that Plaintiffs provided were: 8 On January 8, 2024 Samsung Model No. NE58K9850WS/AA, while being used in a foreseeable manner as the primary range/stove in the kitchen 9 of Plaintiffs’ family home, located 15801 Horseless Carriage Drive, Redding, CA 96001, started a fire. The fire destroyed the house and its 10 contents and resulted in bodily injury to all Plaintiffs other than Neil Liebick, who was away on a business trip. Plaintiff’s [sic] purchased the 11 product from Costco in or about 2023. After the fire, this model electric range was subject to a voluntary product recall by Samsung because the 12 front-mounted knobs can be activated through accidental contact by people or pets. That defect caused this fire. 13 (Id. at 16.) Plaintiffs originally filed suit in the Superior Court of California, 14 County of Shasta. (Id. at 1.) Defendants then timely removed to federal court 15 based on diversity jurisdiction. (Id. at 2.) 16 Defendants now bring a joint motion to dismiss, arguing that the 17 Complaint does not satisfy the pleading standards under Federal Rules of Civil 18 Procedure 8(a)(2) and 12(b)(6). (Mot. at 1, ECF No. 10.) Plaintiffs oppose, 19 contending that they have satisfied these pleading standards.1 (Opp’n, ECF No. 20 14.) Pursuant to Local Rule 230(g), this Motion is submitted without oral 21 argument. 22 LEGAL STANDARD 23 A party may move to dismiss for “failure to state a claim upon which relief can 24 be granted.” Fed. R. Civ. P. 12(b)(6). The motion may be granted only if the 25 complaint lacks a “cognizable legal theory or sufficient facts to support a cognizable 26 27 1 Plaintiffs ask the Court to take judicial notice of litigation involving Defendant Samsung. (Opp’n at 5.) 28 Because the Court need not consider this litigation to reach its decision, the request is denied as moot. 1 legal theory.” Mendiondo v. Centinela Hosp. Med. Ctr., 521 F.3d 1097, 1104 (9th Cir. 2 2008). While the Court assumes all factual allegations are true and construes “them 3 in the light most favorable to the nonmoving party,” Parks Sch. of Bus., Inc. v. 4 Symington, 51 F.3d 1480, 1484 (9th Cir. 1995), the motion must be granted if the 5 complaint’s allegations do not “plausibly give rise to an entitlement to relief,” Ashcroft 6 v. Iqbal, 556 U.S. 662, 679 (2009). 7 A complaint need contain only a “short and plain statement of the claim 8 showing that the pleader is entitled to relief,” Fed. R. Civ. P. 8(a)(2), not “detailed 9 factual allegations,” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). However, 10 this rule demands more than unadorned accusations; “sufficient factual matter” must 11 make the claim at least plausible. Iqbal, 556 U.S. at 678. In the same vein, conclusory 12 or formulaic recitations of elements alone do not suffice. Id. “A claim has facial 13 plausibility when the plaintiff pleads factual content that allows the court to draw the 14 reasonable inference that the defendant is liable for the misconduct alleged.” Id. 15 DISCUSSION 16 I. Products Liability 17 A. Stating a Claim 18 A plaintiff may recover for a products liability claim under a theory of strict 19 liability or negligence. Trejo v. Johnson & Johnson, 13 Cal. App. 5th 110, 125 (2017). 20 To succeed under either theory, a plaintiff must prove: (1) that the product was 21 defective; and (2) that the defect existed when the product left the hands of the 22 manufacturer. Daly v. General Motors Corp., 20 Cal.3d 725, 758 n.1 (1978). 23 Additionally, a plaintiff must show “a substantial probability that the design defect, 24 and not something else, caused the plaintiff’s injury.” Stephen v. Ford Motor Co., 134 25 Cal. App. 4th 1363, 1373 (2005). 26 While Plaintiffs allege that Defendant Samsung issued a voluntary recall, they 27 do not plead that their range in particular had any defect, or that a defect existed 28 when it left Defendant Samsung. Even if Plaintiffs satisfied these elements, they fall 1 far short of plausibly stating that “the design defect, and not something else, caused” 2 their injury. See id. Plaintiffs summarily allege the defect “caused” the fire, which is a 3 legal conclusion that the Court is not bound to accept as true. See Notice of Removal 4 at 16; Iqbal, 556 U.S. at 678. Similarly, Plaintiffs plead that the electric range “started 5 a fire,” but they provide no factual allegations supporting this conclusory allegation. 6 (See Notice of Removal at 16.) The Complaint is devoid of any factual allegations 7 showing that the electric range started the fire, much less that a fire was due to a 8 defect. As Defendants point out, the Complaint “says nothing about how the fire 9 began, whether the range was on, how it may have been activated, or how it was 10 involved in the fire.” (See Reply at 3, ECF No. 17.) Because Plaintiffs fail to 11 adequately allege causation, this claim must be dismissed. 12 B. Theory of Liability 13 “Under California law, there are three ways to hold a manufacturer strictly liable 14 for injuries caused by its product: (1) if the product is defectively manufactured; (2) if 15 it is defectively designed; or (3) if it is distributed without sufficient warnings or 16 instructions about its potential for harm.” Karlsson v. Ford Motor Co., 140 Cal. App. 17 4th 1202, 1208 (2006) (citation omitted).

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Bluebook (online)
Liebick v. Samsung Electronics America, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/liebick-v-samsung-electronics-america-inc-caed-2025.