Safeco Insurance Company Of America v. Air Vent, Inc.

CourtDistrict Court, D. Nevada
DecidedJuly 25, 2022
Docket2:20-cv-01579
StatusUnknown

This text of Safeco Insurance Company Of America v. Air Vent, Inc. (Safeco Insurance Company Of America v. Air Vent, 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
Safeco Insurance Company Of America v. Air Vent, Inc., (D. Nev. 2022).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Safeco Insurance Company of America, Case No.: 2:20-cv-01579-JAD-NJK

4 Plaintiff

5 v. Order Granting Partial Summary Judgment in Favor of Safeco and Denying 6 Air Vent, Inc., et al., Powermax’s Motion to Dismiss

7 Defendants [ECF Nos. 62, 69, 77]

8 and all other parties and claims

9 Roger Himka purchased from Home Depot and installed in his home an attic-cooling fan 10 that ultimately failed, causing a fire and damage to his home. He filed a claim with his home 11 insurer plaintiff Safeco Insurance Company of America, which covered the damage and paid 12 Himka $250,581.60. In an effort to recoup that loss, Safeco sues the fan’s manufacturer, Air 13 Vent, Inc., for negligence and strict products liability. Air Vent in turn filed a third-party 14 complaint against component-part manufacturers and distributors Powermax Electric Company; 15 Chien Luen Industries; and King of Fans, Inc., alleging that the third-party defendants are jointly 16 and vicariously liable to Air Vent if the fan is found to be defective and Air Vent liable to 17 Safeco. Air Vent and Safeco now crossmove for summary judgment on the products-liability 18 claim, and Powermax moves to dismiss for lack of personal jurisdiction. Because Air Vent’s 19 motion relies on law inapplicable to a product-defect claim, I deny it. But I grant partial 20 summary judgment in Safeco’s favor because it has established that no material factual disputes 21 exist and that it is entitled to judgment as a matter of law. I deny Powermax’s motion to dismiss 22 because I find that the company is subject to this court’s specific personal jurisdiction. And I 23 refer this case to the magistrate judge for a mandatory settlement conference. 1 Discussion 2 I. Safeco and Air Vent’s crossmotions for summary judgment [ECF Nos. 62, 69] 3 A. Summary-judgment standard 4 Summary judgment is appropriate when the pleadings and admissible evidence “show

5 that there is no genuine issue as to any material fact and that the movant is entitled to judgment 6 as a matter of law.”1 “By its very terms, this standard provides that the mere existence of some 7 alleged factual dispute between the parties will not defeat an otherwise properly supported 8 motion for summary judgment; the requirement is that there be no genuine issue of material 9 fact.”2 A fact is material if it could affect the outcome of the case.3 10 On summary judgment, the court must view all facts and draw all inferences in the light 11 most favorable to the nonmoving party.4 So the parties’ burdens on an issue at trial are critical. 12 When the movant bears the burden of proof, “it must come forward with evidence [that] would 13 entitle it to a directed verdict if the evidence went uncontroverted at trial.”5 If it does, the burden 14 shifts to the nonmoving party, who “must present significant probative evidence tending to

15 support its claim or defense.”6 But when the moving party does not bear the burden of proof on 16

17 1 See Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986) (citing Fed. R. Civ. P. 56(c)). The court’s ability to grant summary judgment on certain issues or elements is inherent in Federal 18 Rule of Civil Procedure (FRCP) 56. See Fed. R. Civ. P. 56(a). Although Safeco and Air Vent don’t style their motions as ones for partial summary judgment, because it appears that neither 19 mentions the negligence claim, I construe them as requesting summary judgment on the products-liability claim only. 20 2 Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248–49 (1986). 21 3 Id. at 249. 22 4 Kaiser Cement Corp. v. Fischbach & Moore, Inc., 793 F.2d 1100, 1103 (9th Cir. 1986). 5 C.A.R. Transp. Brokerage Co. v. Darden Rests., Inc., 213 F.3d 474, 480 (9th Cir. 2000) 23 (quoting Houghton v. South, 965 F.2d 1532, 1536 (9th Cir. 1992)). 6 Id. 1 the dispositive issue at trial, it is not required to produce evidence to negate the opponent’s 2 claim—its burden is merely to point out the evidence showing the absence of a genuine material 3 factual issue.7 The movant need only defeat one element of a claim to garner summary judgment 4 on it because “a complete failure of proof concerning an essential element of the nonmoving

5 party’s case necessarily renders all other facts immaterial.”8 “When simultaneous cross-motions 6 for summary judgment on the same claim are before the court, the court must consider the 7 appropriate evidentiary material identified and submitted in support of”—and against—“both 8 motions before ruling on each of them.”9 9 B. Safeco is entitled to summary judgment on its products-liability claim. 10 1. This fan defect is a product defect, not a construction defect. 11 In its summary-judgment motion, Air Vent contends that the damage to the Himka home 12 caused by the defective fan gives rise to a construction-defect claim under Nevada Revised 13 Statutes (NRS) Chapter 40, which contains a pre-suit notice-and-opportunity-to-repair 14 requirement that Safeco did not satisfy.10 That failure, Air Vent argues, is “[f]atal” to Safeco’s

15 claims and thus the court must grant Air Vent summary judgment on them.11 Safeco responds 16 17 18 7 Celotex, 477 U.S. at 323. 19 8 Id. at 322. 20 9 Tulalip Tribes of Wash. v. Washington, 783 F.3d 1151, 1156 (9th Cir. 2015) (citing Fair Hous. Council of Riverside Cnty., Inc. v. Riverside Two, 249 F.3d 1132, 1134 (9th Cir. 2001)). 21 10 ECF No. 62. NRS Chapter 40 defines constructional defect as “includ[ing], without limitation, the design, construction, manufacture, repair[,] or landscaping of . . . an alteration of or addition 22 to an existing residence [that] presents an unreasonable risk of injury to a person or property; or [that] is not completed in a good and workmanlike manner and proximately causes physical 23 damage to the residence . . . .” Nev. Rev. Stat. § 40.615. 11 ECF No. 62 at 7–8. 1 that Air Vent misconstrues its claims and that, under the Restatement (Second) of Torts, a defect 2 in a fan is a defect in a product and not in construction, so Chapter 40 is inapplicable here.12 3 “[W]hether a particular item or instrumentality is a product for purposes of strict 4 liability” is a question of law.13 Nevada courts look to the Second and Third Restatements of

5 Torts for guidance on products-liability law.14 Under the Third Restatement, “[a] product is 6 tangible personal property distributed commercially for use or consumption.”15 And comment d 7 to § 402A of the Second Restatement includes as products “an automobile, a tire, an airplane, a 8 grinding wheel, a water heater, a gas stove, a power tool, a riveting machine, a chair, and . . . 9 insecticide.”16 More than 20 years ago, in Calloway v.

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