Talford v. Fisher-Price CA2/8

CourtCalifornia Court of Appeal
DecidedJanuary 27, 2025
DocketB326573
StatusUnpublished

This text of Talford v. Fisher-Price CA2/8 (Talford v. Fisher-Price CA2/8) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Talford v. Fisher-Price CA2/8, (Cal. Ct. App. 2025).

Opinion

Filed 1/27/25 Talford v. Fisher-Price CA2/8 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION EIGHT

WILLIAM TALFORD et al., B326573

Plaintiffs and Appellants, (Los Angeles County Super. Ct. No. 20STCV21836) v.

FISHER-PRICE, INC., et al.,

Defendants and Respondents.

APPEAL from a judgment of the Superior Court of Los Angeles County, William Highberger, Judge. Affirmed.

Blank Rome, Gregory M. Bordo, Jonathan A. Loeb, Ricky M. Guerra; Calcaterra Law, Regina M. Calcaterra and Anjori Mitra for Plaintiffs and Appellants.

Shook, Hardy & Bacon, Steven B. Weisburd; Carlton Fields and Kim S. Zeldin for Defendants and Respondents.

_________________________ In October 2014, four-month-old Liam Talford died while in a Rock ‘n Play Sleeper (RNPS sleeper) manufactured and distributed by defendants and respondents Fisher-Price, Inc. and Mattel, Inc. In 2019, defendants issued a voluntary recall of the RNPS sleeper and in June 2020, Liam’s parents, William and Susan Talford (plaintiffs and appellants), filed this action in California well after the applicable North Carolina statutes of limitations had run on all their causes of action. Defendants moved for summary judgment on the ground that the action was barred by the statute of limitations. The Talfords opposed the motion, relying on the tolling doctrines of equitable estoppel and fraudulent concealment, and on the continuing wrong and discovery exceptions to the statutes of limitations. The trial court granted summary judgment in favor of defendants because the Talfords had “failed to show there is a triable issue of material fact that any tolling applies under North Carolina law.” This appeal followed. The Talfords contend they raised triable issues of material fact as to whether the doctrines of equitable estoppel and fraudulent concealment apply. They further contend the facts show that their fraudulent concealment, fraudulent misrepresentation and negligent misrepresentation causes of action did not accrue until the RNPS sleeper was recalled in 2019. In addition, the Talfords contend the trial court erred in finding that all of their claims fall under the statute of limitations for wrongful death. Finally, they contend the trial court erred by not specifying the reasons it granted summary judgment. Finding no error, we affirm the judgment.

2 BACKGROUND On October 20, 2014, William Talford placed Liam in the RNPS sleeper in the master bedroom and went to another room to watch television. Susan Talford was out walking the family dog. At some point, the Talfords’ 10-year-old daughter told her father that Liam did not look right. William Talford found Liam in the RNPS sleeper, with his head tilted down and to the right; his skin looked blue. Talford called 911 and attempted CPR, but when first responders arrived at the house Liam was dead. The Talfords put Liam’s RNPS sleeper in their attic and threw away the RNPS sleeper belonging to his twin sister Willow. Their explanations for these acts varied. At one point, William Talford stated he threw away Willow’s RNPS sleeper rather than give it to a charity or another family because he “thought that thing had something to do with my son’s death.” Two years later in 2016, the Office of the Chief Medical Examiner issued a report opining that the cause of Liam’s death was Sudden Infant Death Syndrome (SIDS). In April 2019, defendants recalled the RNPS sleeper. The recall notice stated: “Infant fatalities have occurred in [RNPS sleepers], after the infants rolled from their back to their stomach or side while unrestrained, or under other circumstances.” Defendants also stated: “We stand by the safety of our products. However, due to reported incidents in which the product was used contrary to the safety warnings and instructions, we have decided to conduct a voluntary recall of the [RNPS sleeper].” On June 5, 2020, six years after Liam’s death, the Talfords filed this action, alleging 11 causes of action for

3 • strict liability (negligent design); • strict liability (failure to warn); • negligence; • gross negligence; • breach of express warranty; • fraudulent concealment; • fraud (intentional misrepresentation); • negligent misrepresentation; • violation of California’s Unfair Competition Law; • negligent infliction of emotional distress; and • wrongful death. The Talfords also alleged the statutes of limitations had been tolled by the delayed discovery rule and the doctrines of estoppel, fraudulent concealment, and continuing act. Defendants moved for summary judgment on statute of limitations grounds. The trial court granted the motion, ruling that North Carolina law controlled the statutes of limitations, and under North Carolina law the two-year wrongful death statute of limitations governed all causes of action. The court also ruled that all causes of action were barred by the statute of limitations: “The North Carolina statute has no discovery exception for latent or non-apparent injuries. King v. Cape Fear Memorial Hospital, Inc. (N.C.Ct.App. 1989) 385 S.E.2d 812, [814]. Moving party has shown that the first 10 claims are controlled by North Carolina’s wrongful death statute, despite the various names given to the claims in the pleading. The 11th C/A [sic] for fraud is nominally subject to a three-year statute [of limitations] with a possibility of delayed discovery, but the prayer for relief is expressly compensation for wrongful death, not a refund for the cost of a fraudulently marketed product so the wrongful death

4 limitations period must control under North Carolina law. Burcl v. North Carolina Baptist Hospital, Inc. (N.C. 1982) [293] S.E.2d 85, 87; Killian v. Southern Railway Co. (N.C. 1901) 38 S.E. 873, 874.” The trial court concluded: “Plaintiff has failed to show there is a triable issue of material fact that any tolling applies under North Carolina law. The death of a child, while most regrettable, is not analyzed as a ‘continuing wrong.’ ” DISCUSSION We review a trial court’s grant of summary judgment de novo. (Shiver v. Laramee (2018) 24 Cal.App.5th 395, 400.) A motion for summary judgment is properly granted “if all the papers submitted show that there is no triable issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” (Code Civ. Proc.,1 § 437c, subd. (c).) “A triable issue of material fact exists only if ‘the evidence would allow a reasonable trier of fact to find the underlying fact in favor of the party opposing the motion in accordance with the applicable standard of proof.’ ” (Shiver, at p. 400.) “A party may move for summary judgment in an action or proceeding if it is contended that the action has no merit or that there is no defense to the action or proceeding.” (§ 437c, subd. (a)(1).) “A cause of action has no merit if either of the following exists: [¶] (1) One or more of the elements of the cause of action cannot be separately established, even if that element is separately pleaded. [¶] (2) A defendant establishes an affirmative defense to that cause of action.” (Id., subd. (o).) The statute of

1 Undesignated statutory references are to the Code of Civil Procedure.

5 limitations is such a defense. (Cucuzza v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Board of Regents of Univ. of State of NY v. Tomanio
446 U.S. 478 (Supreme Court, 1980)
Palmer v. Borg-Warner Corp.
838 P.2d 1243 (Alaska Supreme Court, 1992)
Ragsdale v. Kennedy
209 S.E.2d 494 (Supreme Court of North Carolina, 1974)
King v. CAPE FEAR MEMORIAL HOSP., INC.
385 S.E.2d 812 (Court of Appeals of North Carolina, 1989)
Friedland v. Gales
509 S.E.2d 793 (Court of Appeals of North Carolina, 1998)
Tin Originals, Inc. v. Colonial Tin Works, Inc.
391 S.E.2d 831 (Court of Appeals of North Carolina, 1990)
Matthieu v. Piedmont Natural Gas Company
152 S.E.2d 336 (Supreme Court of North Carolina, 1967)
Freese v. Smith
428 S.E.2d 841 (Court of Appeals of North Carolina, 1993)
Moore v. Coachmen Industries, Inc.
499 S.E.2d 772 (Court of Appeals of North Carolina, 1998)
Thompson v. Soles
263 S.E.2d 599 (Supreme Court of North Carolina, 1980)
Carcano v. JBSS, LLC
684 S.E.2d 41 (Court of Appeals of North Carolina, 2009)
Dalton v. Camp
548 S.E.2d 704 (Supreme Court of North Carolina, 2001)
State Auto Insurance v. Blind
650 S.E.2d 25 (Court of Appeals of North Carolina, 2007)
Phelps-Dickson Builders, LLC v. Amerimann Partners
617 S.E.2d 664 (Court of Appeals of North Carolina, 2005)
Harton v. Harton
344 S.E.2d 117 (Court of Appeals of North Carolina, 1986)
Stamm v. Salomon
551 S.E.2d 152 (Court of Appeals of North Carolina, 2001)
Cucuzza v. City of Santa Clara
128 Cal. Rptr. 2d 660 (California Court of Appeal, 2002)
Glue-Fold, Inc. v. Slautterback Corp.
98 Cal. Rptr. 2d 661 (California Court of Appeal, 2000)
Santa Barbara Pistachio Ranch v. Chowchilla Water District
105 Cal. Rptr. 2d 856 (California Court of Appeal, 2001)
Killian v. Southern Railway Co.
38 S.E. 873 (Supreme Court of North Carolina, 1901)

Cite This Page — Counsel Stack

Bluebook (online)
Talford v. Fisher-Price CA2/8, Counsel Stack Legal Research, https://law.counselstack.com/opinion/talford-v-fisher-price-ca28-calctapp-2025.