Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Products Liability

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Plaintiff’s Mazda3 sedan caught fire one month after Plaintiff purchased the vehicle. Plaintiff brought this product liability action against Mazda Motor of America, Inc. and Cartwright Auto, LLC, claiming that a defect in the car’s fuel system caused the fire that, in turn, caused Plaintiff to suffer injuries. The trial court granted summary judgment for Defendants on the basis that Plaintiff failed to produce competent expert testimony to support his claim of defect. Plaintiff appealed, arguing that he could prove his case based on an unspecified defect under the malfunction theory of products liability and without expert testimony. The Appellate Court affirmed, concluding (1) Plaintiff failed to raise the malfunction theory in the trial court and thus did not preserve it for appellate review; and (2) Plaintiff’s specific defect claims required expert testimony, and Plaintiff failed to produce this evidence. The Supreme Court affirmed, holding that Plaintiff did not properly preserve his malfunction theory of liability claim for appellate review, and therefore, the Appellate Court did not err in declining to review the malfunction theory claim on appeal. View "White v. Mazda Motor of Am., Inc." on Justia Law
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Plaintiffs brought two separate actions alleging that Hazel Smart died as a result of a defective catheter used in her dialysis treatment at Greater Waterbury Gambro HealthCare. The trial court consolidated the two actions, which brought claims sounding in negligence, medical malpractice, loss of consortium, and products liability. During pretrial proceedings, the trial court imposed monetary sanctions on Plaintiffs for failure to comply with a discovery order. Plaintiffs appealed. The appellate court dismissed the appeal for lack of subject matter jurisdiction, finding that the trial court's discovery order was not an appealable final judgment. The Supreme Court affirmed, holding that the appellate court properly dismissed the appeal, as the trial court's order did not constitute an appealable final judgment. View "Incardona v. Roer" on Justia Law

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Plaintiff, Metropolitan Property and Casualty Insurance Company, brought a product liability action against Defendant, Deere and Company, claiming that a lawn tractor manufactured by Defendant contained a manufacturing defect in its electrical system that caused a fire resulting in the destruction of the home of Plaintiff's insureds. Following a jury trial, the trial court rendered judgment in favor of Plaintiff. The Supreme Court reversed, holding (1) a plaintiff may base a product liability action on the "malfunction theory," which allows a jury to rely on circumstantial evidence to infer that a product that malfunctioned was defective at the time it left the manufacturer's or seller's control if the plaintiff establishes certain elements; and (2) the trial court erred in denying Defendant's motion for a directed verdict because Plaintiff's evidence in the present case was insufficient to establish its products liability claim. View "Metro. Prop. & Cas. Ins. Co. v. Deere & Co." on Justia Law