Watson, M. v. Baby Trend, Inc.

2024 Pa. Super. 5, 308 A.3d 860
CourtSuperior Court of Pennsylvania
DecidedJanuary 12, 2024
Docket2356 EDA 2022
StatusPublished
Cited by5 cases

This text of 2024 Pa. Super. 5 (Watson, M. v. Baby Trend, Inc.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Watson, M. v. Baby Trend, Inc., 2024 Pa. Super. 5, 308 A.3d 860 (Pa. Ct. App. 2024).

Opinion

J-A24020-23

2024 PA Super 5

MICHAEL G. WATSON, : IN THE SUPERIOR COURT OF INDIVIDUALLY AND AS : PENNSYLVANIA ADMINISTRATOR OF THE ESTATE OF : VICTORIA R. WATSON AND MARITA : FARAN WATSON : : Appellant : : : No. 2356 EDA 2022 v. : : : BABY TREND, INC., LAUREN : LANDGREBE AND JOHN DOES 1-10

Appeal from the Order Entered August 3, 2022 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): 210802189

BEFORE: STABILE, J., DUBOW, J., and SULLIVAN, J.

OPINION BY DUBOW, J.: FILED JANUARY 12, 2024

Appellants, Michael G. Watson, individually and as the Administrator of

the Estate of Victoria R. Watson, and Marita Faran Watson, appeal from the

August 3, 2022 Order entered in the Philadelphia County Court of Common

Pleas sustaining the preliminary objections to venue filed by Appellee, Baby

Trend, Inc. (“Baby Trend”). Appellants challenge the order sustaining Baby

Trend’s preliminary objections to venue and transferring the case to Bucks

County, as well as the orders denying discovery requests and a motion to

overrule Baby Trend’s objections to Appellants’ subpoenas. After careful

review, we affirm. J-A24020-23

The relevant facts and procedural history are as follows. Appellants’

infant daughter died of asphyxiation while sleeping in a car seat manufactured

by Baby Trend and under the care of her babysitter, defendant Lauren

Landgrebe. Appellants purchased the car seat from Babies R Us in February

2017. Appellants reside in Bucks County and the cause of action arose there.

Baby Trend is a California-based corporation with no registered offices in

Pennsylvania.

On October 12, 2021, Appellants filed an Amended Complaint in the

Philadelphia County Court of Common Pleas asserting Products Liability/Strict

Liability, Negligence, and Breach of Warranty claims against Baby Trend.1

Preliminary Objections

On October 20, 2021, Baby Trend filed preliminary objections to the

Amended Complaint on the basis of improper venue.2 Baby Trend contended

that venue was not proper in Philadelphia County because Appellants do not

live in Philadelphia County and did not allege that they purchased the car seat

in Philadelphia County, the cause of action did not arise in Philadelphia County,

and Baby Trend does not conduct “substantial, continuous, and systemic

business in Philadelphia County.” Preliminary Objections, 10/20/21, at ¶¶ 3-

____________________________________________

1 Appellants also asserted a Negligence claim against Ms. Landgrebe. Ms. Landgrebe is not a party to this appeal.

2 Baby Trend substantiated the averments set forth in the Preliminary Objections with reference to the attached “Declaration of Brad Mattarocci[,] Vice President of Baby Trend Inc.” Appellants deposed Mr. Mattarocci on January 14, 2022.

-2- J-A24020-23

6, 10. With respect to Baby Trend’s business activities in Philadelphia County,

Baby Trend averred that it does not own any real estate in Philadelphia, does

not have any employees in Philadelphia, the alleged defective product was not

manufactured, designed, or marketed from Philadelphia, its business model is

to distribute products through big-box retailers like Walmart or Target, none

of whom have distribution centers in Philadelphia, and that less than one

percent of its total sales are generated in Philadelphia. Id. at ¶ 12-16, 18,

21.

On November 9, 2021, Appellants filed a response in opposition to Baby

Trend’s preliminary objections in which they, inter alia, requested that the trial

court defer ruling on the preliminary objections to permit the parties to engage

in discovery pertaining to Baby Trend’s business activities in Philadelphia

County. On November 22, 2021, the trial court entered a Rule to Show Cause

permitting the parties to conduct discovery and submit supplemental briefs

limited to the issue of venue.

Appellants’ Motion to Compel Discovery

On December 2, 2021, Appellants served Baby Trend with Requests for

Production of Documents Relating to Venue. In Appellants’ Request No. 8,

they sought “documents showing the amount or percentage of Baby Trend

product sales revenue in . . . states other than Pennsylvania[.]” Discovery

Requests, 12/2/21, at 4. On February 9, 2022, Appellants filed a Motion to

Compel the Production of Documents Reflecting Other-State Sales of

-3- J-A24020-23

[Appellee’s] Products, alleging that Baby Trend failed to provide the

information requested.

On February 24, 2022, Baby Trend filed an answer to Appellants’ motion

to compel asserting that it had “responded to the discovery request to the

best of its ability.” Answer, 2/24/22, at ¶ 13. Further, Baby Trend objected

to this particular document demand as being “overly broad and unduly

burdensome insofar as a request for state[-]specific information of locales

outside of Pennsylvania relate to matters other than those raised in the

pleadings, are neither relevant to this action nor likely to lead to the discovery

of admissible evidence, and are neither material nor necessary to the

prosecution or defense of this action.” Id. Baby Trend contended simply that

Appellants’ “repeated request for sales documents pertaining to other states

is not necessary to determine the context in which venue is proper in

Pennsylvania.” Id.

Following a hearing, on April 19, 2022, the trial court denied Appellants’

motion to compel Baby Trend to produce documents pertaining to its out-of-

state sales data.

Appellants’ Subpoenas

Meanwhile, on January 19, 2022, Appellants served notices of intent to

serve subpoenas on Walmart and Target (the “big-box retailers”) to produce

documents and other discovery related to sales data of Baby Trend products

from: (1) the retailers’ brick-and-mortar stores in Pennsylvania; (2) each

retail store in Philadelphia, Bucks, Montgomery, Chester, and Delaware

-4- J-A24020-23

Counties; (3) online sales to consumers in Pennsylvania; and (4) online sales

in each of the five counties.

On February 9, 2022, Baby Trend filed objections to the notices of intent

to serve subpoenas, asserting that the information Appellants sought was

irrelevant, oppressive, burdensome, vexatious, and unlikely to lead to the

discovery of admissible evidence as to venue because the sales data requested

implicates not Baby Trend’s business activities, but the business activities of

the big-box retailers, who are resellers of items they purchase wholesale from

Baby Trend.

On February 23, 2022, Appellants filed a Motion to Overrule Baby

Trend’s objections to Appellants’ service of subpoenas. Appellants claimed

that they had “crafted their subpoenas narrowly” and they disputed Baby

Trend’s claim that the information sought was irrelevant to the court’s venue

analysis because Baby Trend does not exercise control over these retailers

who, Baby Trend claimed, were merely resellers of Baby Trend products.

Motion, 2/23/22, at ¶¶ 17, 26-67. Appellants argued, inter alia, that the

information was, in fact, relevant because “[g]iven [that] Baby Trend’s sales

are largely channeled through Walmart and Target, comparative data on its

sales in Pennsylvania counties is needed so the [c]ourt can evaluate Baby

Trend’s Philadelphia sales in full context[.]” Id. at ¶ 34.

On May 23, 2022, the trial court denied Appellants’ motion to overrule

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2024 Pa. Super. 5, 308 A.3d 860, Counsel Stack Legal Research, https://law.counselstack.com/opinion/watson-m-v-baby-trend-inc-pasuperct-2024.