SECURA Insurance Company, as subrogee of Lance Goettl d/b/a TLG Farm Partnership v. Deere & Company, ...

CourtCourt of Appeals of Minnesota
DecidedAugust 19, 2024
Docketa231773
StatusPublished

This text of SECURA Insurance Company, as subrogee of Lance Goettl d/b/a TLG Farm Partnership v. Deere & Company, ... (SECURA Insurance Company, as subrogee of Lance Goettl d/b/a TLG Farm Partnership v. Deere & Company, ...) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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SECURA Insurance Company, as subrogee of Lance Goettl d/b/a TLG Farm Partnership v. Deere & Company, ..., (Mich. Ct. App. 2024).

Opinion

STATE OF MINNESOTA IN COURT OF APPEALS A23-1773

SECURA Insurance Company, as subrogee of Lance Goettl d/b/a TLG Farm Partnership, Appellant,

vs.

Deere & Company, Respondent,

Kibble Equipment LLC, Respondent.

Filed August 19, 2024 Affirmed in part, reversed in part, and remanded; motion denied Harris, Judge

Blue Earth County District Court File No. 07-CV-21-2292

David J. Taylor, Yost & Baill, LLP, Minneapolis, Minnesota (for appellant)

Timothy J. Mattson, Bowman and Brooke, LLP, Minneapolis, Minnesota; and

Amanda E. Heitz (pro hac vice), Bowman and Brooke, LLP, Phoenix, Arizona (for respondent Deere & Company)

Mark T. Berhow, Alexander M. Baggio, Hinshaw & Culbertson, LLP, Minneapolis, Minnesota (for respondent Kibble Equipment LLC)

Considered and decided by Harris, Presiding Judge; Schmidt, Judge; and Kirk,

Judge. ∗

∗ Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to Minn. Const. art. VI, § 10. SYLLABUS

A warranty for defects in “material or workmanship” covers only manufacturing

defects and does not include design defects such as a manufacturer’s deliberate addition or

omission of a challenged component.

OPINION

HARRIS, Judge

Appellant-insurer brought this subrogation action following a tractor fire, asserting

claims for breach of express warranty against respondent-manufacturer and negligence

against respondent-dealership. Insurer alleged that the fire was caused by crop debris that

accumulated in the engine compartment due to the lack of engine side shields. The district

court granted the manufacturer’s motion to partially dismiss the breach-of-express-

warranty claim and later granted the manufacturer’s and the dealership’s motions for

summary judgment on all claims.

On appeal, insurer argues that the district court erred by interpreting manufacturer’s

warranty to exclude design defects and by requiring expert testimony to establish

dealership’s standard of care. Because we conclude that the district court correctly

interpreted the warranty, we affirm the dismissal of the breach-of-express-warranty claim

against the manufacturer. We conclude, however, that the district court erred by requiring

expert testimony about the standard of care to sustain the negligence claim against the

dealership. We therefore reverse the dismissal of the negligence claim and remand for

further proceedings.

2 FACTS

After paying a claim of its insured, SECURA as a subrogee sued, following a fire

which destroyed a Deere Model Year 2018.5 RX tractor manufactured by respondent Deere

& Company and obtained from respondent Kibble Equipment LLC, an equipment

dealership. 1 The following facts are based on the record at summary judgment and

presented in the light most favorable to SECURA as the nonmoving party. See

Montemayor v. Sebright Prods., Inc., 898 N.W.2d 623, 628 (Minn. 2017) (describing

summary-judgment standard).

Deere manufactured the Model Year 2018.5 RX tractors while transitioning its

production facility to make its Model Year 2019.5 RX tractors, and thus, the 2018.5 tractors

included some updated features of the 2019.5 tractors. Specifically, the 2018.5 tractor

frames included factory-drilled holes that allowed for the installation of shields on the sides

of the engine compartment. Without such shields, crop debris could accumulate in the

engine compartment and create a fire hazard. The 2019 tractors came with engine shields

installed. Although 2018.5 tractors did not come with engine shields, Deere created an

optional program to install engine shields on 2018.5 tractors in August 2019 and sent notice

of the program to dealerships such as Kibble. The program information identified the

potential for debris to accumulate in the engine compartment.

In November 2019, Kibble provided a Deere 2018.5 tractor that did not have engine

shields to TLG Farm, under its equipment service plan called the Kibble Equipment

1 “John Deere” and “Deere & Company” are the same company under the terms of its warranty.

3 Assurance Plan, while one of TLG Farm’s tractors underwent repairs. The next day, the

tractor caught fire and was destroyed.

Following the fire, SECURA made insurance payments to TLG Farm. SECURA

then sought to enforce Deere’s warranty for the tractor. The warranty stated, “Under these

warranties, John Deere will repair or replace, at its option, any part covered under these

warranties which is found to be defective in material or workmanship during the applicable

warranty term.” After SECURA, Deere, and Kibble participated in inspections of the

tractor, SECURA’s expert determined that the cause of the fire was crop debris igniting in

the engine compartment. Deere’s expert could not conclusively state or rule out that the

fire was caused by crop debris.

SECURA served a complaint on Deere and Kibble. The complaint alleged that

Deere breached its warranty by providing a machine defective in design and/or

manufacture due to the lack of engine shields and that Deere failed to comply with its

obligations under the warranty. In addition, SECURA brought a negligence claim against

Kibble alleging that Kibble “fail[ed] to provide a rental tractor with the fire shields

equipped.”

In November 2021, Deere moved for partial dismissal of SECURA’s breach-of-

express-warranty claim under Minnesota Rules of Civil Procedure 12.02(e) for failure to

state a claim upon which relief can be granted. Deere argued that SECURA’s claim should

be dismissed to the extent that it is based on an alleged design defect because Deere’s

warranty—a warranty for defects in “material or workmanship”—covered only

manufacturing defects, not defects based on intentional design decisions. The district court

4 agreed that the limited warranty unambiguously excluded design defects and thus granted

the partial dismissal of SECURA’s claim for breach of express warranty. The district court

also denied SECURA’s motion to amend the complaint to add strict-liability and

negligence claims against Deere.

Deere moved for summary judgment on the breach-of-express-warranty claim,

arguing that the engine shields were not intended to be included as part of the tractor and

thus their absence did not qualify as a manufacturing defect. Kibble moved for the

summary-judgment dismissal of the negligence claim. Kibble argued it was entitled to

summary judgment because SECURA’s negligence claim was barred by (1) the economic-

loss doctrine, (2) an exculpatory clause in the rental agreement for the tractor, (3) an

indemnity clause in the rental agreement for the tractor, and (4) SECURA’s failure to

establish the applicable standard of care.

SECURA opposed both motions. With respect to Deere’s motion, SECURA argued

that the limitation in Deere’s express warranty violated Minnesota law imposing a

nondelegable duty to design a reasonably safe product. With respect to Kibble’s motion,

SECURA argued that the alleged rental agreement for the tractor was not controlling and

thus SECURA’s recovery was not barred by the economic-loss doctrine or clauses in that

agreement. SECURA also argued that it presented sufficient evidence for a jury to find

that Kibble acted negligently by providing a tractor lacking engine shields without expert

testimony.

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SECURA Insurance Company, as subrogee of Lance Goettl d/b/a TLG Farm Partnership v. Deere & Company, ..., Counsel Stack Legal Research, https://law.counselstack.com/opinion/secura-insurance-company-as-subrogee-of-lance-goettl-dba-tlg-farm-minnctapp-2024.