S.S. v. Peloton Interactive, Inc.

District Court, S.D. California·Decided October 27, 2023·No. 3:21-cv-01367·Unknown

Opinion

7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 S.S., a minor, by and through his Guardian ) Case No.: 3:21-cv-01367-BEN-MMP ad Litem Eunjin Stern; EUNJIN STERN, ) 12 an individual; WILLIAM STERN, an ) ORDER: 13 individual,, ) ) (1) DENYING-IN-PART Plaintiffs, 14 ) DEFENDANT’S PRETRIAL BRIEF; 15 v. ) and ) 16 PELOTON INTERACTIVE, INC., a ) (2) DENYING PLAINTIFFS’ Delaware corporation; DOES 1 through 17 50, inclusive, ) PRETRIAL BRIEF ) 18 Defendant. ) [ECF Nos. 92, 93] 19 ) 20

21 I. INTRODUCTION 22 Plaintiff S.S., a minor, by and through his Guardian ad Litem Eunjin Stern (“S.S.”); 23 Eunjin Stern, an individual (“Mrs. Stern”); and William Stern, an individual (“Mr. Stern”) 24 (collectively, “Plaintiffs”) bring this action against Defendant Peloton Interactive, Inc., a 25 Delaware corporation (“Peloton”) for injuries allegedly sustained in connection with 26 Defendant’s Tread+ treadmill (the “Tread+”). Before the Court are the parties’ respective 27 Briefs outlining various pretrial objections. See ECF Nos. 92, 93. The briefing was 28 1 submitted on the papers without oral argument pursuant to Civil Local Rule 7.1(d)(1) and 2 Rule 78(b) of the Federal Rules of Civil Procedure. ECF No. 102. After considering the 3 papers submitted, supporting documentation, and applicable law, the Court: (1) DENIES- 4 IN-PART Peloton’s Pretrial Brief; and (2) DENIES Plaintiffs’ Pretrial Brief. 5 II. BACKGROUND 6 A. Statement of Facts 7 According to the Complaint, around March 2020, while Mr. Stern was exercising on 8 the Tread+, his three-year-old son, S.S., approached the rear of the machine without Mr. 9 Stern’s knowledge. ECF No. 1-2 (“Compl.”) at 3, ¶ 1; 5, ¶ 10. S.S. was pulled under the 10 450-pound Tread+, with Mr. Stern’s added body weight of 150 pounds. Id. As soon as 11 Mr. Stern realized his child was stuck underneath the Tread+, he dismounted and attempted 12 to remove him, but S.S. was repeatedly sucked back under the Tread+. Id. at 3, ¶ 1. Mrs. 13 Stern came to help. Id. Both parents attempted to pull S.S. from underneath the Tread+ 14 by his hands, shoulders, and torso, but they were unable to successfully remove him. Id. 15 at 3, ¶ 2. Mr. Stern attempted to lift the Tread+ but this failed as well. Id. Mr. Stern was 16 able to remove S.S. when Mrs. Stern triggered the Tread+’s ripcord, which caused the 17 Tread+ to come to a halt. Id. at 3–4, ¶ 2. Plaintiffs allege that S.S. sustained injuries along 18 his arms and shoulders, including but not limited to contusions along his torso, stomach, 19 and ribs, as well as a laceration and permanent scarring to his stomach. Id. This is referred 20 to as “the Incident” by the parties. 21 Around May 2021, Peloton issued a recall of its Tread+ Treadmills after the United 22 States Consumer Product Safety Commission (the “CPSC”) cautioned parents against the 23 use of the machines due to the risk of injury and death. Id. at 4, ¶ 3. The CPSC learned of 24 numerous other incidents of children being sucked beneath the treadmills. Id. Plaintiffs 25 allege that Peloton “publicly confessed to the issues affecting its machines,” concluding 26 that it “should have engaged more productively with [the] [CPSC] from the outset.” Id. 27 Peloton added that it “made a mistake in [its] initial response to the” CPSC’s request that 28 the Tread+ be recalled. Id. 1 Plaintiffs further allege how Peloton “became the subject of an investigation by the 2 CPSC.” Id. at 8, ¶ 25. “On April 17, 2021, after investigating the death of at least one 3 child and dozens of injuries like those sustained by [S.S.], the CPSC issued a warning to 4 consumers, which [Peloton] initially refused to support.” Id. “Specifically, the CPSC 5 advised consumers to ‘[s]top using the Peloton Tread+ if there are small children or pets at 6 home,” and the “CPSC issued the warning because there is no safe way to use the Treadmill 7 in a home where children are present.” Id. Plaintiffs allege that initially, Peloton “rejected 8 the CPSC’s recommendation to stop using the Treadmill,” calling the CPSC statement 9 “inaccurate and misleading.” Id. at 8, ¶ 26. Finally, Plaintiffs allege that Peloton made 10 this “representation despite numerous documented injuries to minors, with the intent to 11 encourage the ongoing use and purchase of the Treadmill despite its knowledge that the 12 Treadmill could injure children.” Id. at 8–9, ¶ 26. 13 B. Procedural History 14 On May 7, 2021, Plaintiffs filed suit against Peloton in state court, alleging six causes 15 of action for: (1) negligence; (2) negligent infliction of emotional distress by S.S. as a direct 16 victim; (3) negligent infliction of emotional distress by Mr. and Mrs. Stern as bystanders; 17 (4) intentional misrepresentation; (5) negligent misrepresentation; and (6) intentional 18 concealment. See Compl. Defendant removed the case to this Court. 19 In August 2021, Peloton filed a Motion to Compel Arbitration, see ECF No. 11, 20 which this Court granted-in-part, compelling Mr. Stern and Peloton to arbitration to 21 determine the question of arbitrability—Mrs. Stern and S.S., however, are not bound by 22 the arbitration agreement. See generally ECF No. 15. The parties engaged in discovery 23 and on January 18, 2023, Peloton filed a Motion to Exclude Expert Testimony, see ECF 24 No. 65, which this Court denied, see ECF No. 87. 25 After receiving the parties’ proposed pretrial order and various objections to witness 26 testimony and evidentiary exhibits, the Court ordered that the parties brief their objections. 27 The parties filed Briefs concerning their respective objections, which are now before the 28 Court. For all practical purposes, the Briefs seek to exclude certain evidence at trial. As 1 such, the Court applies the motion in limine standard in analyzing the various requests. 2 III. LEGAL STANDARD 3 Rulings on motions in limine fall entirely within this Court’s discretion. United 4 States v. Bensimon, 172 F.3d 1121, 1127 (9th Cir. 1999) (citing Luce v. United States, 469 5 U.S. 38, 41–42 (1984)). “Evidence is excluded on a motion in limine only if the evidence 6 is clearly inadmissible for any purpose.” Mathis v. Milgard Manufacturing, Inc., No. 16- 7 cv-2914-BEN-JLB, 2019 WL 482490, at *1 (S.D. Cal. Feb. 7, 2019) (Fresenius Med. Care 8 Holdings, Inc., v. Baxter Int’l, Inc., 2006 WL 1646113, at *3 (N.D. Cal. June 12, 2006)). 9 “If evidence is not clearly inadmissible, evidentiary rulings should be deferred until trial to 10 allow questions of foundation, relevancy, and prejudice to be resolved in context.” See 11 Mathis, 2019 WL 482490, at *1 (citing Bensimon, 172 F.3d at 1127). “Denial of a motion 12 in limine does not mean that the evidence contemplated by the motion will be admitted at 13 trial. Instead, denial means that the court cannot, or should not, determine whether the 14 evidence in question should be excluded before trial.” Mathis, 2019 WL 482490, at *1 15 (citation omitted); see also McSherry v. City of Long Beach, 423 F.3d 1015, 1022 (9th Cir. 16 2005) (rulings on motions in limine are subject to change when trial unfolds). 17 IV. DISCUSSION 18 Peloton’s Pretrial Brief seeks to exclude at trial, Plaintiffs’: (1) negligence per se 19 theory; (2) testimony for of CPSC witnesses; (3) CPSC exhibits; and (4) S.S.’s direct victim 20 claim of negligent infliction of emotional distress. ECF No. 93. Plaintiffs’ Pretrial Brief 21 seeks to exclude at trial the opinions of Peloton’s expert Dr. Christopher Thompson. ECF 22 No. 92. The Court rules on each request in turn. 23 A.

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