Mullen v. Bodum USA, Inc.

CourtDistrict Court, S.D. New York
DecidedJune 23, 2025
Docket1:23-cv-01166
StatusUnknown

This text of Mullen v. Bodum USA, Inc. (Mullen v. Bodum USA, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mullen v. Bodum USA, Inc., (S.D.N.Y. 2025).

Opinion

USDC SDNY UNITED STATES DISTRICT COURT DOCUMENT SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED WADE MULLEN, DOC #: DATE FILED: _ 6/23/2025 Plaintiff, -against- 23 Civ. 1166 (AT) BODUM USA, INC., OPINION AND ORDER Defendant. ANALISA TORRES, District Judge: Plaintiff, Wade Mullen, brings this products liability action against Defendant, Bodum USA, Inc. (“Bodum”), seeking damages for injuries he sustained when his Bodum French press shattered and sprayed him with hot coffee. See generally Compl., ECF No. 1. Before the Court are Bodum motion for summary judgment and motion to exclude expert evidence submitted by Mullen concerning the cause of the French press’ shattering. Mot., ECF No. 51. For the reasons stated below, both motions are granted in part and denied in part. BACKGROUND! In the spring of 2020, Mullen’s wife gifted him a Bodum eight-cup Brazil Model French press, which she purchased from Target. Def. 56.1 9 1-2, ECF No. 59. For the next nine or ten months, Mullen used it daily without incident. Jd. §§ 2, 4-5. On the morning of March 7, 2021, however, soon after pouring hot water into the French press’ carafe, Mullen noticed the carafe’s glass sides start to crack. Jd. 1, 6-9. He picked up the French press by its handle to pour its contents into the sink, at which point it broke apart, spilling hot water and coffee grounds on Mullen’s legs and feet. Jd. 9-10. Mullen’s feet turned red and tender, and he visited his

! These facts are taken from Bodum’s Rule 56.1 statement, Mullen’s response, and the parties’ declarations and accompanying exhibits, unless otherwise noted. Citations to a paragraph of Bodum’s Rule 56.1 statement also include Mullen’s response.

primary care physician the following day for treatment. Id. ¶¶ 12–14. The physician noted that Mullen had “faint erythema”—skin redness—on his shins and feet but that “no skin breakdown [was] present.” Def. Ex. C at 6.2 On February 10, 2023, Mullen filed this suit against Bodum. Compl. Over the following year and a half, the parties engaged in discovery. Before the Court are Bodum’s motion for

summary judgment and motion to exclude the expert opinions of Mingxi Zheng, an engineer who inspected the shattered French press. Mot.; see Mem., ECF No. 53; Opp., ECF No. 57; Reply, ECF No. 61; Report, Def. Ex. 12. DISCUSSION I. Medical Causation A. Legal Standard A party is entitled to summary judgment if it can establish that there “is no genuine dispute as to any material fact” and that it “is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247–48 (1986); Celotex Corp. v.

Catrett, 477 U.S. 317, 322–26 (1986). A genuine dispute exists “if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson, 477 U.S. at 248. The moving party bears the initial burden of informing the Court of the absence of a genuine dispute of material fact by citing particular evidence in the record. Fed. R. Civ. P. 56(c)(1); Celotex, 477 U.S. at 323–24; Koch v. Town of Brattleboro, 287 F.3d 162, 165 (2d Cir. 2002). In making this showing, the party may rely on “materials in the record, including depositions, documents, electronically stored information, affidavits or declarations, stipulations . . . , admissions, interrogatory answers, or other materials.” Fed. R. Civ. P.

2 Citations to “Def. Ex.” are to the exhibits attached to the declaration of Jason A. Wheeler at ECF No. 54. 56(c)(1)(A). If the moving party meets its initial burden, the burden shifts to the opposing party to establish a genuine dispute of material fact. Beard v. Banks, 548 U.S. 521, 529 (2006). The Court views all facts “in the light most favorable to the non-movant, resolving all ambiguities in [his] favor.” Borley v. United States, 22 F.4th 75, 78 (2d Cir. 2021). B. Analysis

Bodum argues that Mullen cannot establish medical causation because he fails to offer expert medical evidence linking the spilled coffee to physical injury. See Mem. at 11–13. Mullen, in response, claims that the hot coffee burned him and that expert evidence is not necessary to prove that fact. Opp. at 22–24. “It is black-letter law that a plaintiff, seeking to prevail on a personal injury claim, must show causation, meaning that the defendant’s conduct was the proximate cause of [his] injuries.” In re Mirena IUS Levonorgestrel-Related Prods. Liab. Litig. (No. II), 387 F. Supp. 3d 323, 336 (S.D.N.Y. 2019) (citation omitted). Sometimes, expert evidence is necessary to demonstrate such causation. See Riad v. Porsche Cars N. Am., Inc., No. 18 Civ. 5175, 2024 WL 3606315, at

*3 (E.D. Pa. July 30, 2024) (explaining that Pennsylvania courts generally require expert medical evidence in personal injury actions and listing cases).3 But not always. Expert evidence is not necessary when a factfinder is “as capable of comprehending the primary facts and of drawing correct conclusions from them as are witnesses possessed of special or peculiar training.” Wills v. Amerada Hess Corp., 379 F.3d 32, 46 (2d Cir. 2004) (quoting Salem v. U.S. Lines Co., 370 U.S. 31, 35 (1962)). Thus, a plaintiff need not adduce expert evidence “if there is an obvious causal relationship between the alleged negligent act and the injury complained of,” Riad, 2024

3 The Court applies Pennsylvania law because Pennsylvania, where Mullen acquired the French press, lives, and makes coffee, has the greatest interest in this matter. See Fin. One Pub. Co. Ltd. v. Lehman Bros. Special Fin., Inc., 414 F.3d 325, 336–37 (2d Cir. 2005); Compl. ¶¶ 1–4. WL 3606315, at *2 n.7 (citation omitted); see Hamil v. Bashline, 392 A.2d 1280, 1285 (Pa. 1978), in other words, when an injury is “either an immediate and direct or the natural and probable result of the alleged negligent act,” Lattanze v. Silverstrini, 448 A.2d 605, 608 (Pa. Super. Ct. 1982) (citation omitted). Bodum points out that Mullen did not seek emergency medical services or receive

specific treatment for burns and that he therefore cannot demonstrate that the spilled coffee injured him.4 Mem. at 11–13; see Mullen Dep. at 72:4–73:25, ECF No. 58-1; Def. Ex. C at 6 (physician’s note that Mullen had “no skin breakdown[] present” the day after the incident). The record establishes, however, that the spilled coffee immediately caused Mullen’s affected skin to become “red and tender,” and that when Mullen visited his primary care physician the following day, the doctor observed “faint erythema” on Mullen’s shins and feet and told Mullen to apply ointment if his skin bothered him. Mullen Dep. at 72:20–73:25; Def. Ex. C at 6. Mullen also reported that the skin on the bottom of his foot began to blister within a week of the incident. Mullen Dep. at 72:17–24. The connection between Mullen spilling hot coffee on his lower

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Mullen v. Bodum USA, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mullen-v-bodum-usa-inc-nysd-2025.