Richey v. Axon Enterprises, Inc.

CourtDistrict Court, D. Nevada
DecidedJanuary 29, 2020
Docket3:19-cv-00192
StatusUnknown

This text of Richey v. Axon Enterprises, Inc. (Richey v. Axon Enterprises, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richey v. Axon Enterprises, Inc., (D. Nev. 2020).

Opinion

3 UNITED STATES DISTRICT COURT

4 DISTRICT OF NEVADA

5 * * *

6 DOUGLAS RICHEY, Case No. 3:19-cv-00192-MMD-CLB

7 Plaintiff, ORDER v. 8

9 AXON ENTERPRISES, INC,

10 Defendant.

11 12 I. SUMMARY 13 This action stems from a dispute relating to the alleged defective design of certain 14 models of conducted electrical weapons (“CEWs”) manufactured by Defendant Axon 15 Enterprises, Inc. (“Axon”). Before the Court is Axon’s motion to dismiss (“Motion”) Plaintiff 16 Douglas Richey’s complaint asserting federal and state law claims (“Complaint”) (ECF 17 No. 1). (ECF No. 29.) For the reasons discussed below, the Motion is granted in part and 18 denied in part. 19 II. BACKGROUND 20 The following background facts are adopted from the Complaint. 21 Axon, formerly Taser International, Inc., manufactures CEWs (also known as 22 “Tasers”). (ECF No. 29 at 10.) Axon has developed the Pulse, X2, and X26P models of 23 CEWs, and has previously manufactured the now discontinued C2 model of CEW. (Id.) 24 Each of Axon’s CEW models are covered with an express limited warranty (“Warranty”). 25 (ECF No. 1 at 9; ECF No. 29 at 10.) The Warranty represents that the models will be “free 26 from defects in workmanship and materials for a period of ONE (1) YEAR from the date 27 of receipt.” (Id.) The Warranty also provides that if the company receives a “valid warranty 28 claim” within the warranty period, Axon will “repair or replace the product” and that Axon’s 2 product, at [Axon’s] discretion.” (ECF No. 1 at 9; ECF No. 29 at 10.) 3 In 2016, Richey purchased a C2 model CEW from Axon. (ECF No. 1 at 6.) In 4 October of that year, Richey fired the weapon, but it malfunctioned when the prongs 5 ejected only one to two feet. (Id.) Richey then notified Axon customer service of the issue. 6 (Id.) Axon shipped a Pulse model CEW to Richey at his home in Corte Madera, CA as a 7 replacement for his malfunctioning model. (ECF No. 29-1 at 7.)1 On January 18, 2017, 8 while the safety switch on the CEW was in the “safe” position, the CEW discharged in 9 Richey’s pocket without him pulling the trigger. (ECF No. 1 at 6.) The barbs of the CEW 10 stuck into Richey’s jacket but, while he had to rip his jacket pocket to free the barbs, he 11 was not personally harmed in the incident. (Id.) 12 After inspecting the device, Richey determined that the safety mechanism had 13 become disengaged. (Id. at 6–7.) Specifically, Richey confirmed that the safety 14 mechanism could be disengaged from the “safe” position to the “armed” position by 15 moving the safety lever only a fraction of the way up with little pressure applied. (Id.) That 16 same day, Richey contacted Axon’s customer service, informing them of the misfire. (Id. 17 at 8.) On January 26, 2017, an Axon representative told Richey that “our engineers are 18 currently aware of the safety switch activation [issue] and are working on a solution.” (Id.) 19 While Axon offered to send Richey two replacement barb cartridges, Axon did not repair 20 or replace Richey’s Pulse CEW. (Id.) On February 22, 2017, counsel for Richey sent a 21 letter (“Letter”) to Axon informing it of the defective safety mechanism in the Pulse, X2 22 and X26P CEWs. (Id. at 20–24.) To date, Axon has not repaired or replaced Richey’s 23 Pulse model CEW. (Id. at 10.) 24 On June 25, 2018, Richey filed a putative class action complaint in the United 25 States District Court for the Northern District of California (“California Complaint”). (EFC 26 No. 29-1.) On August 9, 2018, Richey voluntarily dismissed the California Complaint. 27 1The Court takes judicial notice of Richey’s complaint regarding these same facts 28 filed in the Northern District of California. See Fed. R. Evid. 201; see also infra Section 2 X26P models suffered from a design defect that caused the CEWs to accidentally arm 3 and discharge. (ECF No. 1 at 9.) Richey asserted the following claims against Axon: 4 violation of the federal Magnuson-Moss Warranty Act (“the Act”); fraudulent omission; 5 unjust enrichment; and violation of the Nevada Deceptive Trade Practices Act (“NDTPA”). 6 (ECF No. 1.) On July 8, 2019, Axon moved to dismiss all of Richey’s claims under Federal 7 Rules of Civil Procedure 12(b)(1) and (b)(6). (ECF No. 29.) 8 III. LEGAL STANDARDS 9 A. 12(b)(1) Legal Standard 10 Rule 12(b)(1) allows defendants to seek dismissal of a claim or action for a lack of 11 subject matter jurisdiction. Although the defendant is the moving party in a motion to 12 dismiss brought under Rule 12(b)(1), the plaintiff is the party invoking the court’s 13 jurisdiction. As a result, the plaintiff bears the burden of proving that the case is properly 14 in federal court. See McCauley v. Ford Motor Co., 264 F.3d 952, 957 (9th Cir. 2001) (citing 15 McNutt v. General Motors Acceptance Corp., 298 U.S. 178, 189 (1936)). Plaintiff’s burden 16 is subject to a preponderance of the evidence standard. See Leite v. Crane Co., 749 F.3d 17 1117, 1121 (9th Cir. 2014). 18 Federal courts are courts of limited jurisdiction. See Owen Equip. & Erection Co. 19 v. Kroger, 437 U.S. 365, 374 (1978). A federal court is presumed to lack jurisdiction in a 20 particular case unless the contrary affirmatively appears. See Stock West, Inc. v. 21 Confederated Tribes of the Colville Reservation, 873 F.2d 1221, 1225 (9th Cir. 1989). 22 “Because subject matter jurisdiction goes to the power of the court to hear a case, it is a 23 threshold issue and may be raised at any time and by any party.” Mallard Auto. Grp., Ltd. 24 v. United States, 343 F. Supp. 2d 949, 952 (D. Nev. 2004) (citing Fed. R. Civ. P. 12(b)(1)). 25 B. 12(b)(6) Legal Standard 26 A court may dismiss a plaintiff’s complaint for “failure to state a claim upon which 27 relief can be granted.” Fed. R. Civ. P. 12(b)(6). A properly pleaded complaint must provide 28 “a short and plain statement of the claim showing that the pleader is entitled to relief.” 2 Rule 8 does not require detailed factual allegations, it demands more than “labels and 3 conclusions” or a “formulaic recitation of the elements of a cause of action.” Ashcroft v. 4 Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 U.S. at 555). “Factual allegations 5 must be enough to rise above the speculative level.” Twombly, 550 U.S. at 555. Thus, to 6 survive a motion to dismiss, a complaint must contain sufficient factual matter to “state a 7 claim to relief that is plausible on its face.” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 8 U.S. at 570). 9 In Iqbal, the Supreme Court clarified the two-step approach district courts are to 10 apply when considering motions to dismiss. First, a district court must accept as true all 11 well-pleaded factual allegations in the complaint; however, legal conclusions are not 12 entitled to the assumption of truth. Id. at 678. Mere recitals of the elements of a cause of 13 action, supported only by conclusory statements, do not suffice. Id. at 678. Second, a 14 district court must consider whether the factual allegations in the complaint allege a 15 plausible claim for relief. Id. at 679. A claim is facially plausible when the plaintiff’s 16 complaint alleges facts that allow a court to draw a reasonable inference that the 17 defendant is liable for the alleged misconduct. Id. at 678.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

McNutt v. General Motors Acceptance Corp.
298 U.S. 178 (Supreme Court, 1936)
Klaxon Co. v. Stentor Electric Manufacturing Co.
313 U.S. 487 (Supreme Court, 1941)
Owen Equipment & Erection Co. v. Kroger
437 U.S. 365 (Supreme Court, 1978)
Astoria Federal Savings & Loan Ass'n v. Solimino
501 U.S. 104 (Supreme Court, 1991)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Johnson v. California
543 U.S. 499 (Supreme Court, 2005)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Clapper v. Amnesty International USA
133 S. Ct. 1138 (Supreme Court, 2013)
Bates v. United Parcel Service, Inc.
511 F.3d 974 (Ninth Circuit, 2007)
Mexia v. Rinker Boat Co., Inc.
174 Cal. App. 4th 1297 (California Court of Appeal, 2009)
Magpali v. Farmers Group, Inc.
48 Cal. App. 4th 471 (California Court of Appeal, 1996)
Mallard Automotive Group, Ltd. v. United States
343 F. Supp. 2d 949 (D. Nevada, 2004)
Gonzalez-Rios v. Hewlett Packard PR Co.
749 F.3d 15 (First Circuit, 2014)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)
Hardenburgh v. Lockwood
25 Barb. 9 (New York Supreme Court, 1856)

Cite This Page — Counsel Stack

Bluebook (online)
Richey v. Axon Enterprises, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/richey-v-axon-enterprises-inc-nvd-2020.