Reynolds v. MJC America Ltd

CourtDistrict Court, E.D. Wisconsin
DecidedFebruary 28, 2025
Docket1:23-cv-00738
StatusUnknown

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

Bluebook
Reynolds v. MJC America Ltd, (E.D. Wis. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

CYNTHIA REYNOLDS,

Plaintiff,

v. Case No. 23-CV-738

MJC AMERICA, LTD., et al.,

Defendants.

DECISION AND ORDER

1. Background Cynthia Reynolds suffered a fire in her Oshkosh, Wisconsin, home on December 4, 2020. (ECF No. 58, ¶ 12.) Reynolds alleges that the fire was caused by a dehumidifier manufactured and sold by the defendants, MJC America, Ltd, Gree USA, Inc., Hong Kong Gree Electric Appliance Sales, LTD, and Gree Electric Appliances Inc of Zhuhai (referred to here collectively as Gree). (ECF No. 54, ¶¶ 4, 21.) Reynolds’s insurer, American Family Insurance, paid her $146,015.40 for expenses related to the fire. (ECF No. 58, ¶ 12.) American Family assigned to Reynolds any subrogation claim it may have, in exchange for a lien in the amount it paid. Reynolds then brought this action against Gree. The court has subject matter jurisdiction because the parties are completely diverse and the amount in controversy exceeds $75,000. See 28 U.S.C. § 1332(a). Pending before the court are various motions. Reynolds seeks summary judgment that Gree is liable under Wisconsin’s strict product liability statute, Wis. Stat. § 895.047, and that “she is entitled to claim punitive damages.” (ECF No. 28.)

Gree filed its own motion for summary judgment (ECF No. 35.) It asks the court to find that American Family is the real party in interest as to the amount it paid Reynolds and that Reynolds’s potential punitive damages must be related to only her expenses beyond those compensated by American Family. (ECF No. 37 at 3.) Gree (technically only Gree USA, Inc. and MJC America, Ltd) also filed a

motion to compel asking, in material part, the court to find that the plaintiff has waived her objections to Gree’s requests for production and interrogatories, and compelling the plaintiff to provide complete, objection free, responses, and extending the deadline for discovery. (ECF No. 46.) 2. Motions for Summary Judgment “A motion for summary judgment is a contention that the material facts are undisputed and the movant is entitled to judgment as a matter of law.” Hotel 71 Mezz

Lender Ltd. Liab. Co. v. Nat'l Ret. Fund., 778 F.3d 593, 601 (7th Cir. 2015). The court does not “weigh the evidence and determine the truth of the matter” but rather “determine[s] whether there is a genuine issue for trial.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986) The movant has the burden to show that summary judgment is appropriate. Weaver v. Champion Petfoods USA Inc., 3 F.4th 927, 934 (7th Cir. 2021). The court

will “read the facts and draw all reasonable inferences in the light most favorable to the non-moving party.” Flowers v. Kia Motors Fin., 105 F.4th 939, 945 (7th Cir. 2024). Nonetheless, the non-movant must go beyond mere allegations and conclusions and instead support its contentions with proper documentary evidence. Foster v. PNC

Bank, 52 F.4th 315, 320 (7th Cir. 2022); Weaver, 3 F.4th at 934. Speculation is insufficient to create a genuine dispute of material fact. Id. If the movant sustains its burden and shows both that there are disputed material facts and that it is entitled to judgment as a matter of law “[t]he court shall grant summary judgment ….” Fed. R. Civ. P. 56(a). 2.1. Real Party in Interest / Subrogation

“An action must be prosecuted in the name of the real party in interest.” Fed. R. Civ. P. 17(a)(1). “The ‘real party in interest’ is the person who possesses the right or interest to be enforced through litigation, and the purpose of this procedural rule is to protect the defendant against a subsequent action by the party actually entitled to recover.” RK Co. v. See, 622 F.3d 846, 850 (7th Cir. 2010) (citing Fed. R. Civ. P. 17(a) advisory comm.’s note (2009); Rawoof v. Texor Petroleum Co., Inc., 521 F.3d 750, 756 (7th Cir. 2008); 4 Moore’s Federal Practice § 17.10 (3d. 2009)).

The general rule is that if an insurer has paid all of the insured’s claim, then the insurer, not the insured, is the real party in interest under Federal Rule of Civil Procedure 17(a). Krueger v. Cartwright, 996 F.2d 928, 931 (7th Cir. 1993). Accordingly, Gree argues that American Family is the real party in interest and only it can prosecute this action. Reynolds argues that American Family never had a right to subrogation because under the policy language, subrogation is discretionary and American Family never exercised that right. (ECF No. 31 at 11-12.)

But whether American Family had a right to subrogation, contractual or otherwise, is inconsequential because American Family assigned to Reynolds any subrogation claim it had, subject to a lien for the $146,015.40 it paid. (ECF No. 58, ¶ 12.) Gree argues that this assignment and lien procedure was an improper scheme

to increase American Family’s recovery by opening the door to punitive damages. Gree notes that American Family retained Attorney Ronald W. Harmeyer to pursue its claim against Gree. Harmeyer then facilitated the assignment and lien agreement between American Family and Reynolds. A condition of that agreement was that Reynolds retain Harmeyer to prosecute a claim against Gree. Reynolds’s deposition testimony revealed that she has been only nominally involved in the action. She expressed no understanding of the assignment and lien agreement, did not review

her own discovery responses, and did not appear to understand the nature and extent of her claims. From Gree’s perspective, although prosecuted in Reynolds’s name, this is an action prosecuted for American Family’s benefit by American Family’s attorney. Gree acknowledges that Reynolds would be a real party in interest for any additional damages she sustained that were not compensated by American Family. See Krueger, 996 F.2d at 932 (stating that if an insurer pays only part of an insured’s

loss, the insurer and insured “should appear in the litigation in their own names”) (quoting United States v. Aetna Cas. & Sur. Co., 338 U.S. 366, 381 (1949)). Reynolds may be able to obtain punitive damages, but only in relation to her additional damages. But Gree argues that Reynolds has not presented evidence of any such

additional damages and therefore, not only is Reynolds unable to seek punitive damages, she is also not even a real party in interest. An insurer may waive or assign its right to subrogation, Jindra v. Diederich Flooring, 181 Wis. 2d 579, 598, 511 N.W.2d 855, 860 (1994) (quoting Leonard v. Bottomley, 210 Wis. 411, 417, 245 N.W. 849, 851 (1933)), subject to the caveat that assignments contrary to public policy are void, Am. Ins. Co. v. Milwaukee, 51 Wis. 2d

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