Richter v. ITW Ransburg Electrostatic Systems Group

178 F. App'x 605
CourtCourt of Appeals for the Eighth Circuit
DecidedApril 28, 2006
Docket05-2832
StatusUnpublished

This text of 178 F. App'x 605 (Richter v. ITW Ransburg Electrostatic Systems Group) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richter v. ITW Ransburg Electrostatic Systems Group, 178 F. App'x 605 (8th Cir. 2006).

Opinion

*606 [UNPUBLISHED]

PER CURIAM.

Gerald and Charlene Richter appeal the district court’s 1 adverse grant of summary judgment in the Richters’ strict liability and negligence actions against ITW Rans-burg Electrostatic Systems Group (“Rans-burg”) and American Industrial Corporation (“AIC”). 2 The Richters’ claims arise from a high-voltage electrical shock that Gerald Richter received while working as a paint line operator for Andersen Windows/Andersen Corporation (“Andersen”) in Bayport, Minnesota.

We review de novo the district court’s grant of summary judgment, applying the same standard that the district court applied. Sperry v. Bauermeister, Inc., 4 F.3d 596, 597 (8th Cir.1993). Summary judgment is appropriate where “the record, when viewed in the light most favorable to ... the nonmoving party, shows that there is no genuine issue of material fact and that ... the moving party ... is entitled to judgment as a matter of law.” Id.

The district court granted summary judgment to AIC and Ransburg because, in the district court’s view: (i) the record did not contain facts sufficient to create a genuine issue of material fact as to whether Richter’s injuries were proximately caused by AIC or Ransburg’s actions; (ii) the record did not contain facts sufficient to create a genuine issue of material fact as to whether AIC and Ransburg were responsible for alleged defects in Andersen’s electrostatic painting system; and (iii) Andersen’s miswiring constituted an intervening, superseding cause of Richter’s injury.

After a careful review of the record and the parties’ briefs, we conclude that the district court correctly determined that there is no genuine issue of material fact concerning whether AIC or Ransburg proximately caused Richter’s injuries and that an extended opinion would add nothing of substance to the district court’s well-reasoned analysis of that issue. Under Minnesota law, proof of proximate causation is an essential element of any design defect or negligence claim. Patton v. Newmar Corp., 538 N.W.2d 116, 119-20 (Minn.1995) (design defect); see also Hudson v. Snyder Body, Inc., 326 N.W.2d 149, 157 (Minn.1982) (negligence). As a result, our agreement with the district court’s opinion concerning proximate causation is sufficient to warrant affirmance of the district court’s judgment, and we need not reach the other bases for summary judgment set forth by the district court.

Accordingly, we affirm. See 8th Cir. R. 47B.

1

. The Honorable Ann D. Montgomery, United States District Judge for the District of Minnesota.

2

. Richter’s amended complaint also contained a cause for breach of warranty. However, Richter failed to argue before this Court that the district court erred when it granted summary judgment to the defendants on Richter's warranty claim. Accordingly, we treat Richter’s warranty claim as abandoned. See, e.g., Jasperson v. Purolator Courier Corp., 765 F.2d 736, 740-41 (8th Cir. 1985).

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Related

Patton v. Newmar Corp.
538 N.W.2d 116 (Supreme Court of Minnesota, 1995)
Hudson v. Snyder Body, Inc.
326 N.W.2d 149 (Supreme Court of Minnesota, 1982)

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Bluebook (online)
178 F. App'x 605, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richter-v-itw-ransburg-electrostatic-systems-group-ca8-2006.