Ronald Fronckowiak, as an individual, and as Personal Representative of the Estate of Felix Fronckowiak, deceased, and Rebecca Jaeger, an individual v. Kia America, Inc., a California corporation

CourtDistrict Court, M.D. Florida
DecidedApril 15, 2026
Docket8:24-cv-00863
StatusUnknown

This text of Ronald Fronckowiak, as an individual, and as Personal Representative of the Estate of Felix Fronckowiak, deceased, and Rebecca Jaeger, an individual v. Kia America, Inc., a California corporation (Ronald Fronckowiak, as an individual, and as Personal Representative of the Estate of Felix Fronckowiak, deceased, and Rebecca Jaeger, an individual v. Kia America, Inc., a California corporation) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ronald Fronckowiak, as an individual, and as Personal Representative of the Estate of Felix Fronckowiak, deceased, and Rebecca Jaeger, an individual v. Kia America, Inc., a California corporation, (M.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

RONALD FRONCKOWIAK, as an individual, and as Personal Representative of the Estate of FELIX FRONCKOWIAK, deceased, and REBECCA JAEGER, an individual,

Plaintiffs,

v. Case No. 8:24-cv-863-WFJ-CPT

KIA AMERICA, INC., a California corporation,

Defendant. ___________________________________/

ORDER Before the Court is Defendant Kia’s Motion for Summary Judgment, Dkt. 56, to which Plaintiffs responded in opposition. Dkt. 59. Defendant Kia replied, Dkt. 60, and Plaintiffs filed a sur-reply. Dkt. 77. The Court considers Defendant Kia’s supplemental authority, Dkt. 80, and Plaintiffs’ corresponding supplemental brief. Dkt. 81. Additionally before the Court are Defendant Kia America, Inc.’s (“Kia”) Motion to Exclude the testimony of Plaintiffs’ expert witnesses Peter A. Hancock and David J. Bizzak, Dkt. 57, to which Plaintiffs responded in opposition, Dkt. 58- 1, and Plaintiffs’ Motion for Leave to file a Supplemental Declaration of Peter A. Hancock, Dkt. 78, to which Defendant responded in opposition. Dkt. 83. The Court heard oral argument regarding all pending motions on February 13, 2026. Dkt. 79. Upon careful consideration, the Court grants-in-part Defendant Kia’s Motion to

Exclude, grants Defendant Kia’s Motion for Summary Judgment, and denies Plaintiffs’ Motion for Leave to File a Supplemental Declaration. BACKGROUND

This dispute arises from the death of 88-year-old Ronald Fronckowiak (the “Decedent”) by carbon monoxide toxicity. Dkt. 32 ¶¶ 9–11. On the evening of February 22, 2022, Rebecca Jaeger (“Jaeger”), age 72, drove the Decedent in his 2017 Kia Sorento (the “vehicle”) from the hospital—where he was being treated for

a dislocated shoulder and confusion—to the couple’s rental home in Spring Hill, Florida. Dkt. 56-1 at 7–8. Jaeger had never driven the vehicle before February 22, 2022. Id. at 14. Decedent rode in the right-front passenger seat, id. at 9, while Jaeger

parked the vehicle in the garage of their rental home. Id. at 10. She then closed the garage door. Id. at 10–11. Jaeger exited the vehicle, assisted the Decedent out of the vehicle, and they both proceeded inside with the key fob, which was ultimately left on the kitchen table. Id.; see Dkt. 56-4 at 11. Tragically, they left the car running in

the enclosed single-car garage. See Dkt. 56-4 at 12 (showing a police photo of the vehicle in the garage). The next morning, officers from the Hernando County Sheriff’s Office

performed a wellness check on the couple after the Decedent’s family had not made contact with him. Dkt. 32 ¶ 10; Dkt. 56-4 at 11. Decedent was found deceased in the room next to the garage, and it was later determined that he died from carbon

monoxide toxicity. Dkt. 32 ¶¶ 9–10; Dkt. 56-4 at 11. Jaeger was found alive but unconscious in a room further from the garage, having sustained injuries due to carbon monoxide exposure. Dkt. 32 ¶¶ 10, 11; Dkt. 56-4 at 11.

The 2017 Kia Sorento is designed with keyless ignition technology, but does not include an automatic shutoff feature. Dkt. 56-4 at 43. 83% of 2017 model year vehicles were found to not offer an automatic shutoff feature, and 91% did not include this as a standard feature. Id. at 45. The National Highway Traffic Safety

Administration (“NHTSA”)—the national automotive regulatory agency— considered automatic shutoff, but decided not to require it. Id. at 34–36 (describing the Notice of Proposed Rule Making (“NPRM”) for NHTSA Federal Motor Vehicle

Safety Standard (“FMVSS”) 114, which proposed requiring “an audible alert to sound outside the vehicle if the propulsion system is running,” but explicitly declined to propose “regulatory text to require . . . automatic shut off systems”). The 2017 Kia Sorento does include an external auditory warning chime,

which sounds when the vehicle is left running. Id. at 49. This warning complied with the relevant industry standards of 2017; specifically, Society of Automotive Engineers’ (“SAE”) recommended practice J2948. See id. at 33–34 (“An externally

audible or visual alert shall be activated when the starting system is in ACCESSORY, ELECTRICAL, or RUN MODE, all doors become closed, and an electronic key code carrying device (e.g., keyfob) is not present in the vehicle.”).

The chime was measured to last 5.0 seconds at 73.8 decibels. Id. at 46–51. When compared with 14 peer 2017 model SUVs, this was found to be the longest and the second loudest external auditory warning. Id.

On February 21, 2024, Plaintiffs brought the instant action in state court, Dkt. 1-3 at 6–17, which was later removed to the United States District Court for the Middle District of Florida. Dkt. 1. The operative complaint alleges claims of: strict liability—manufacturing defect (Count I); strict liability—design defect (Count II);

strict liability—failure to warn (Count III); negligence (Count IV); and negligence— failure to recall (Count V). Dkt. 32. LEGAL STANDARD

Summary judgment is only appropriate when there is “no genuine issue as to any material fact [such] that the moving party is entitled to a judgment as a matter of law.” Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986); see Fed R. Civ. P. 56(a). An issue of fact is “material” if it might affect the outcome of the case under the

governing law. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). It is “genuine” if the evidence could lead a reasonable jury to find for the non-moving party. See id.; see also Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S.

574, 587 (1986). The moving party has the burden of proving the absence of a genuine issue of material fact, and all factual inferences are drawn in favor of the non-moving party.

See Allen v. Tyson Foods Inc., 121 F.3d 642, 646 (11th Cir. 1997); Pennington v. City of Huntsville, 261 F.3d 1262, 1265 (11th Cir. 2001) (noting a court must “review the facts and all reasonable inferences in the light most favorable to the non-

moving party”). Once the moving party satisfies its initial burden, it shifts to the non-moving party to come forward with evidence showing a genuine issue of material fact that precludes summary judgment. Bailey v. Allgas, Inc., 284 F.3d 1237, 1243 (11th Cir. 2002); Celotex, 477 U.S. at 324; Fed. R. Civ. P. 56(e), (c).

Speculation or conjecture cannot create a genuine issue of material fact. Cordoba v. Dillard’s, Inc., 419 F.3d 1169, 1181 (11th Cir. 2005). A court may not weigh evidence to resolve a factual dispute; if a genuine issue

of material fact is present, the court must deny summary judgment. Hutcherson v. Progressive Corp., 984 F.2d 1152, 1155 (11th Cir. 1993). Likewise, the court should deny summary judgment if reasonable minds could differ on the inferences arising from undisputed facts. Miranda v. B & B Cash Grocery Store, Inc., 975 F.2d 1518,

1534 (11th Cir. 1992). DISCUSSION I. Count II: Strict Liability—Design Defect

“A design defect claim under Florida law requires ‘[f]irst, that the product is defective; and second, that such defect caused plaintiff’s injuries.’” Cates v.

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Ronald Fronckowiak, as an individual, and as Personal Representative of the Estate of Felix Fronckowiak, deceased, and Rebecca Jaeger, an individual v. Kia America, Inc., a California corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ronald-fronckowiak-as-an-individual-and-as-personal-representative-of-the-flmd-2026.