Tinjak v. Bianchi USA Inc/Cycleurope USA Incs

CourtDistrict Court, S.D. Ohio
DecidedSeptember 16, 2024
Docket2:22-cv-02853
StatusUnknown

This text of Tinjak v. Bianchi USA Inc/Cycleurope USA Incs (Tinjak v. Bianchi USA Inc/Cycleurope USA Incs) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tinjak v. Bianchi USA Inc/Cycleurope USA Incs, (S.D. Ohio 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

ELMEDIN TINJAK, et al.,

: Plaintiffs,

Case No. 2:22-cv-2853

v. Chief Judge Sarah D. Morrison

Magistrate Judge Elizabeth A.

Preston Deavers

BIANCHI USA, INC., et al., :

Defendants.

OPINION AND ORDER After being injured in a bicycle crash, Elmedin Tinjak and his wife filed suit against the bike’s manufacturer, Cycleurope USA, Inc. dba Bianchi USA.1 (Compl., ECF No. 2.) The matter is now before the Court on Bianchi’s Motion for Summary Judgment on the Applicability of Ohio Revised Code § 2315.18 Caps on Non- Economic Damages (Mot. Summ. J., ECF No. 36) and the Tinjaks’ Motion to Exclude Defendants’ Expert Witnesses Not Disclosed in Accordance with Fed. R. Civ. P 26(A) (Mot. Exclude, ECF No. 37). For the reasons below, both motions are GRANTED. I. BACKGROUND Mr. Tinjak has been a life-long cyclist. (Tinjak Dep., ECF No. 35, 16:10–11.) On June 20, 2020, the carbon fiber fork of his brand-new Bianchi bicycle failed, causing him to crash face-first on the pavement. (Tinjak Aff., ECF No. 39-1, ¶¶ 3–4;

1 Backcountry.com LLC was also named as a Defendant, but has since been dismissed from the action. (See ECF No. 25.) see also Tinjak Dep., 27:19–20.) Mr. Tinjak was taken to Riverside Methodist Hospital, where he was treated for a concussion, chest contusions, a fractured vertebra, and multiple complex facial lacerations. (Tinjak Aff., ¶ 6.) In deposition,

Mr. Tinjak described the pain of having gravel removed from his wounds. (Tinjak Dep., 34:6–13.) His “tongue was completely shredded.” (Id., 34:22–23.) His mouth and nose required complex repair, including reattachment of several nerves. (Id., 36:7; see also Tinjak Aff., ¶ 6.) The injury and resulting stitches left scarring on his face and “pockets” of skin between his lip and jaw. (Tinjak Aff., ¶¶ 10, 12; see also ECF No. 39-3.) The injuries Mr. Tinjak sustained that day continue to affect him. The scars

on his face bother him—he used creams to minimize their appearance and keeps facial hair “to hide a lot of” them. (Tinjak Dep., 36:22–37:24.) The pockets in his mouth can accidentally catch food. (Id., 35:17–21.) And he lost sensation in the area around his mouth, which he understands is likely permanent. (Id., 36:8–9; Tinjak Aff., ¶ 18.) Mr. Tinjak’s “biggest issue,” though, is back pain. (Tinjak Dep., 39:20.) He struggles to do things he was once able to do, such as ski and play golf. (Tinjak

Aff., ¶ 9.) He can no longer ride his bike for long periods of time, play sports with his kids for long periods of time, or stand for more than 30–45 minutes. (Id.) The Tinjaks filed this action seeking damages for economic and non-economic loss suffered as a result of the crash. (Compl., ¶ 48.) II. MOTION FOR SUMMARY JUDGMENT Bianchi argues that, as a matter of law, the Tinjaks’ claims are subject to the damage caps in Ohio Rev. Code § 2315.18(B)(2). That statute caps “damages for noneconomic loss” to the greater of $250,000 or three times the economic loss, up to $350,000 per plaintiff or $500,000 per occurrence, unless the loss results from “permanent and substantial physical deformity, loss of use of a limb, or loss of a

bodily organ system” or “[p]ermanent physical functional injury that permanently prevents the injured person from being able to independently care for self and perform life-sustaining activities.” Ohio Rev. Code § 2315.18(B)(2)–(3). Mr. Tinjak opposes the imposition of the caps, arguing that a reasonable jury could find that his injuries constitute a permanent and substantial physical deformity. The Court disagrees. The Ohio Revised Code does not define “permanent and substantial physical

deformity.” Accord Torres v. Concrete Designs Inc., 134 N.E.3d 903, 925 (Ohio Ct. App., 2019). But the Ohio Supreme Court has explained that § 2315.18 limits noneconomic damages “for all but the most serious injuries[.]” Arbino v. Johnson & Johnson, 880 N.E.2d 420, 432 (Ohio 2007); see also id. at 433 (describing the injuries excepted from the damage cap as “catastrophic”). Similarly, this Court has said that “when viewed in the context of the other language in § 2315.18(3)(a), any

‘permanent and substantial physical deformity’ must be ‘severe and objective.’” Sheffer v. Novartis Pharma. Corp., No. 3:12-cv-238, 2014 WL 10293816, at *2 (S.D. Ohio July 15, 2014) (Rice, J.) (quoting Weldon v. Presley, No. 1:10-cv-1077, 2011 WL 3749469 (N.D. Ohio Aug. 9, 2011)). In Sheffer, for example, this Court found that osteonecrosis of the jaw caused by defendant’s products was not severe and objective, despite persistent imperfections and pain in the plaintiff’s jaw. 2014 WL 10293816, at *2. Compare that with White v. Bannerman, where Ohio’s Fifth District Court of Appeals upheld an award above the statutory cap after a car accident caused glass fragments to embed in the plaintiff’s face and sever tendons in

her hands, resulting in severe scarring and limited mobility. Nos. 2009CA00221, 20090CA00245 and 2009CA00268, 2010 WL 3852354 (Ohio Ct. App. Sept. 27, 2010). On the evidence provided, no reasonable jury could conclude that Mr. Tinjak’s injuries rise to the level of a permanent and substantial physical deformity. The scars on Mr. Tinjak’s face are visible. But, based on the photos provided, they are not substantial—especially when “[c]ommon experience readily teaches that many people have some type of scar, from childhood roughhousing or surgery.” Weldon,

2011 WL 3749469, at *6. And although there is evidence that food can lodge into the pockets left by intraoral scarring, and that Mr. Tinjak lost sensation in an area around his mouth, there is no indication that these effects are catastrophic. Mr. Tinjak urges the Court to reserve this issue for a jury, but “courts have not hesitated to decide the issue before trial” when, as here, “it is clear that the statutory exceptions are inapplicable[.]” Sheffer, 2014 WL 10293816, at *2 (further

citation omitted). Bianchi’s Motion is GRANTED. Mr. Tinjak’s recovery for noneconomic losses is subject to the damages caps in Ohio Rev. Code § 2315.18. III. MOTION TO EXCLUDE UNDISCLOSED EXPERT The Tinjaks seek to exclude Greg Dubois as an expert witness for failure to comply with the expert disclosure requirements. (Mot. Exclude.) The Court established a March 31, 2023 deadline for expert disclosures. (Preliminary Pretrial Order, ECF No. 12.) Expert disclosures go beyond just the expert’s identity; a party must also

disclose the expert’s written report. Fed. R. Civ. P. 25(a)(2)(A)–(B). When a party fails to comply with Rule 26(a)’s expert disclosure requirements, Rule 37(c) precludes the noncompliant party from using the “information or witness to supply evidence on a motion, at a hearing, or at a trial, unless the failure was substantially justified or is harmless.” Fed. R. Civ. P. 37(c)(1). The sanction is “self-executing.” Fed. R. Civ. P. 37(c) advisory committee’s note to 1993 Amendment. The party seeking to avoid the Rule 37(c) sanction—here, Bianchi—bears the burden of

showing that its failure to comply with the expert disclosure requirements was harmless or substantially justified. Roberts ex rel. Johnson v.

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Tinjak v. Bianchi USA Inc/Cycleurope USA Incs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tinjak-v-bianchi-usa-inccycleurope-usa-incs-ohsd-2024.