Tracy Burns v. Firman Power Equipment, Inc., et al.

CourtDistrict Court, E.D. Missouri
DecidedMarch 25, 2026
Docket4:25-cv-00442
StatusUnknown

This text of Tracy Burns v. Firman Power Equipment, Inc., et al. (Tracy Burns v. Firman Power Equipment, Inc., et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tracy Burns v. Firman Power Equipment, Inc., et al., (E.D. Mo. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

TRACY BURNS, ) ) Plaintiff, ) ) vs. ) Case No. 4:25-cv-00442-MTS ) FIRMAN POWER EQUIPMENT, ) INC., et al., ) ) Defendants. )

MEMORANDUM AND ORDER This matter is before the Court on Plaintiff Tracy Burns’s Motion to Remand. Doc. [15]. Defendant Firman Power Equipment, Inc. (“Firman”) has filed its Response in Opposition, Doc. [20],1 and Plaintiff filed a Reply in Support, Doc. [21]. This matter is fully briefed and ready for decision. For the reasons that follow, the Court will deny Plaintiff’s Motion. Because the Court concludes that Defendant City of Desloge (the “City”) is fraudulently joined, the Court will enter herewith an Order of Partial Dismissal that dismisses the City from this action without prejudice. I. Background This wrongful-death action arises out of the use of an allegedly defective portable generator during a summer storm. On August 2, 2023, Joy Evon Thurston and her son,

1 Both Plaintiff’s Memorandum in Support of her Motion, Doc. [16], and Firman’s Response in Opposition exceed fifteen numbered pages, and neither party sought leave to file overlength briefs beforehand. This violated the Eastern District of Missouri Local Rules. E.D. Mo. L.R. 4.01(D). The Court warns the parties to follow the requirements of the Local Rules in all aspects of this litigation going forward. Failure to do so may result in sanctions or other disadvantage. Peter Fred Selzer, were at home when severe weather caused a power outage. Doc. [8] ¶ 5. Additionally, rainwater flooded into their basement due to a drainage problem stemming from the City’s “failure to properly construct, implement and/or maintain a proper

sewer/storm management system to drain water from the street.” Id. ¶ 6. Without electricity, Mr. Selzer could not operate his sump pump to drain the basement, so he borrowed a neighbor’s portable generator to supply the necessary power. Id. ¶ 7. That generator was Firman’s Model P03605. Id. ¶ 8. Because the generator could not be used in wet weather, Mr. Selzer chose to place it in a breezeway adjacent to the home. Id.

Tragically, and within a short period of time, the generator produced high levels of carbon monoxide that fatally poisoned Mr. Selzer and Ms. Thurston (together, the “Decedents”). Id. ¶ 11–12. Plaintiff alleges that Mr. Selzer used the generator in a manner that Firman intended or “reasonably anticipated.” Id. ¶ 37. Plaintiff further alleges that carbon monoxide

poisoning is a well-known risk among portable-generator manufacturers like Firman. Id. ¶ 13. In addition, Plaintiff contends that Firman’s Model P03605 is defective as designed because it lacks an automatic shutoff at certain carbon monoxide levels, consistent with industry standards. Id. ¶¶ 24–25, 29, 31, 34. According to Plaintiff, Firman also failed to provide adequate warnings and instructions about the dangers of carbon monoxide

emissions. Id. ¶¶ 35–36. As a result, Plaintiff has suffered the loss of two family members,2 the reasonable value of their services and companionship, and related pecuniary

2 Ms. Thurston was Plaintiff’s mother, and Mr. Selzer was Plaintiff’s brother. Id. ¶ 2. losses and expenses. She also seeks to recover for the fear, pain, and suffering that Decedents experienced. See, e.g., id. ¶ 45. Based on the foregoing, Plaintiff filed a Petition for Wrongful Death against Firman

and the City in St. Francois County Circuit Court. Doc. [8]; see also Mo. Rev. Stat. § 537.080. In it, she asserts what she labels as six counts: (1) Strict Liability – Design/Manufacturing Defect against Firman (Count I); (2) Strict Liability – Failure to Warn against Firman (Count II); (3) Negligence – Design/Manufacturing Defect against Firman (Count III); (4) Negligence – Failure to Warn against Firman (Count IV); (5)

Negligence against the City (Count V); and (6) Dangerous Condition of Public Property against the City (Count VI).3 Soon after service, Firman removed the action to this Court, arguing that federal subject-matter jurisdiction exists pursuant to 28 U.S.C. § 1332(a). Doc. [1] at 4–5 (citing 28 U.S.C. § 1441(a)). Recognizing that § 1332(a) requires complete diversity of citizenship among the parties, Firman contends that Plaintiff both fraudulently

joined and fraudulently misjoined the City to this action, and the Court should therefore disregard the City in its jurisdictional analysis. Id. at 8–18. From Firman’s perspective, once the City is excluded, the remaining parties are completely diverse, and the

3 Technically speaking, Plaintiff has only one claim, a claim for wrongful death under Missouri law. See Lawrence v. Beverly Manor, 273 S.W.3d 525, 528 (Mo. banc 2009) (“The wrongful death statute and the precedent cases clearly consider wrongful death to be a cause of action separate and distinct from the underlying tort.”). The counts she provides are more properly understood as her legal theories that make Defendants liable for Decedents’ deaths. See Smith v. Brown & Williamson Tobacco Corp., 275 S.W.3d 748, 766 (Mo. Ct. App. 2008) (“Under Missouri’s wrongful death statute, ‘the right to sue for wrongful death is conditioned on the fact that the decedent could have maintained an action for damages for the injuries sustained had he or she survived.’”); see also 34B Robert H. Dierker & Richard J. Mehan, Missouri Practice Series § 55:2 (2025 ed.) (explaining that “the elements of a wrongful death action will be identical to the elements of the underlying tort claim, with the significant differences that the wrongful death action entails proof of causation of the decedent’s death, and recoverable damages are those specified in the statute”). requirements of § 1332(a) are satisfied. Id. at 7. Plaintiff disagrees and has filed a Motion to Remand, Doc. [15], arguing that the City is a proper party to this action and thus destroys the complete diversity that § 1332(a) requires, Doc. [16].

II. Legal Standard The party seeking removal and opposing remand bears the burden of establishing federal subject-matter jurisdiction. See In re Bus. Men’s Assur. Co. of Am., 992 F.2d 181, 183 (8th Cir. 1993); see also 28 U.S.C. § 1441(a) (allowing defendants to remove civil, state-court actions “of which the district courts of the United States have original

jurisdiction” to federal court). To establish federal diversity jurisdiction, a removing defendant has to show that the amount in controversy exceeds $75,000, and the action is between “citizens of different States.” 28 U.S.C. § 1332(a). Thus, a state-court action is usually nonremovable if it is between a plaintiff and a defendant who share the same citizenship because “complete diversity” is lacking. OnePoint Sols., LLC v. Borchert, 486

F.3d 342, 346 (8th Cir. 2007). But “[c]ourts have long recognized fraudulent joinder as an exception to the complete diversity rule.” In re Prempro Prods. Liab. Litig., 591 F.3d 613, 620 (8th Cir. 2010).

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