Montoya v. Sloan Valve Company

District Court, E.D. Missouri·Decided June 14, 2022·No. 4:20-cv-01108·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

RODRIGO MONTOYA, ) ) Plaintiff, ) ) v. ) Cause No.: 4:20-CV-01108-AGF ) SLOAN VALVE COMPANY, d/b/a ) FLUSHMATE, ) ) Defendant/Third-Party Plaintiff, ) ) v. ) ) COTTLEVILLE VENTURES, L.L.C., ) ) ) Third-Party Defendant. )

MEMORANDUM AND ORDER This matter is before the Court on a motion to exclude expert testimony in this personal injury lawsuit invoking the Court’s diversity jurisdiction. For the reasons set forth below, the motion will be granted in part and denied in part. BACKGROUND Plaintiff Rodrigo Montoya filed this action against Defendant Sloan Valve Company, d/b/a Flushmate, in August 2020, asserting claims of strict product liability and negligence, after a toilet tank containing a pressure valve manufactured by Sloan exploded while Plaintiff was installing it, causing the lid to strike Plaintiff in the face, resulting in multiple fractures to his jaw, lacerations to his chin, and several broken teeth. The pressure valve in question had been the subject of a product recall and the distribution of repair kits to customers, initiated in June 2012 and expanded in January 2014. Third-party Defendant Cottleville Ventures owned the business premises where

the accident occurred. Cottleville had received repair kits in April 2014 but never installed one in the subject tank, which had been placed in storage for several years. In April 2020, Cottleville hired Plaintiff, a longtime handyman for the business, to replace the tank into service. After Plaintiff installed the tank and reconnected the supply line, the valve failed and the tank exploded as Plaintiff stood over it.

Sloan filed a third-party complaint against Cottleville asserting (1) contributory negligence and indemnification, for Cottleville’s failure to install the repair kit and failure to inform Plaintiff about the recall or the dangerous condition, and (2) negligence per se, for Cottleville’s alleged violation of county and city ordinances requiring licensed plumbers to obtain permits to perform the work that resulted in Plaintiff’s accident.

As relevant to the present motion, Sloan seeks to offer the expert testimony of a master plumber, Mr. Robert Trask, who would opine that Plaintiff’s injury could have been avoided if Cottleville had complied with applicable ordinances by engaging a licensed plumber. Trask is a master plumber with 27 years of experience as the owner of Parkway Construction Services and a former President of the American Subcontractor

Association. He holds a license in St. Charles County where Plaintiff’s accident occurred. In forming his opinions in this case, he reviewed Plaintiff’s complaint and deposition, Sloan’s third-party complaint against Cottleville, the deposition of Sloan’s representative, Lori Feltmate, and the depositions of Cottleville’s representatives, Michael K. Reiter and Michael R. Reiter (father and son). In his report (Doc. 107-2), Trask summarizes the facts as follows. Cottleville hired Plaintiff to remove a toilet tank at its commercial premises and replace the tank

with another containing Sloan’s pressure valve. City and county ordinances, which incorporate the International Building Code, require a licensed plumber to obtain a permit before performing this type of work. Plaintiff is not a licensed plumber. Cottleville did not obtain a permit or hire a licensed plumber to perform the work, thereby violating local ordinances. Cottleville was aware of Sloan’s product recall, as evidenced by the

fact that Cottleville had requested and received repair kits for its toilet tanks containing Sloan pressure valves. However, the tank Plaintiff was instructed to install when he was injured had not been repaired. Trask centrally opines that, had Cottleville hired a licensed plumber, that person would have investigated the product and any manufacturer data and instructions, which would have revealed the recall and related information about

the repair kits to protect against injury. In deposition, when challenged as to whether hiring a licensed plumber would have made a difference, Trask opined: I think it would have made a difference. … If a licensed plumber [had] been asked to perform this specific scope of work, I do not believe that that work would have been done. I don’t believe that a plumber would have installed that particular product, and he certainly would not have installed that product without having also installed the repair kit. … A professional plumber would not have hired an individual that is not a plumber, and that doesn’t have the background or training to do this type of work. There’s a reason that these codes exist. There’s a reason that there are requirements to be licensed. There are reasons that there’s a requirement for training and documentation of that. And there’s a reason that a lot of provisions of the code exist to protect people, including installers. Doc. 107-3 at pp. 7-8 (cleaned up). Throughout his deposition testimony, Trask repeated that a licensed plumber would not have agreed to install the unrepaired toilet and instead would have advised the customer toward a different solution. Doc. 108-1 at pp. 7-10.

Parties’ Arguments Cottleville moves to exclude Trask’s testimony on the following grounds: (1) Trask’s testimony regarding Cottleville’s code violations constitutes an impermissible legal opinion; (2) Trask’s testimony regarding Cottleville’s knowledge of Sloan’s product recalls constitutes impermissible state-of-mind testimony; (3) Trask’s opinion that a

licensed plumber would not have attempted the repair is impermissible speculation; and (4) Trask should not be permitted to testify as to whether Plaintiff installed the tank correctly. Plaintiff joins Cottleville’s motion except to the extent Trask opined that Sloan’s product was indeed defective and caused Plaintiff’s injury, which Plaintiff deems admissible.

In response to Cottleville’s motion, Sloan states that (1) Trask is not offering legal conclusions but rather his expert opinion on plumbing industry standards and practices and the practical reasons for code requirements; (2) Trask is not offering state-of-mind testimony but merely factual context according to Cottleville’s own representatives; (3) Trask’s opinion that a licensed plumber would have taken a different approach is not

speculation but rather informs the jury about industry standards and practices; and (4) Sloan does not intend to solicit Trask’s opinion as to Plaintiff’s performance. In response to Plaintiff’s motion seeking to admit Trask’s opinions on defective design and causation, Sloan objects and moves to strike Plaintiff’s motion as improper, as Sloan did not designate Trask as an expert on such matters. Sloan contends that Plaintiff should instead submit deposition designations for the Court’s consideration upon motions in limine.

Additional facts and arguments are recited below as relevant to particular issues. DISCUSSION Legal Standards The admission of expert testimony in federal court is governed by Federal Rule of Evidence 702. Wagner v. Hesston Corp., 450 F.3d 756, 758 (8th Cir. 2006). Rule 702

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