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Smith v. MTD Products, Inc.

United States District Court, D. Maryland

October 24, 2019

MICHAEL W. SMITH, Plaintiff,
v.
MTD PRODUCTS, INC., et al., Defendants.

          MEMORANDUM

          Catherine C. Blake, United States District Judge.

         This is a case about injuries caused by an allegedly defective snow thrower designed and manufactured by the defendants, MTD Products Inc., MTD Consumer Group Inc., MTD Holdings Inc., and MTD LLC (collectively "MTD").[1] Pending before the court is MTD's motion for summary judgment. For the reasons explained below, the court will deny the motion.

         FACTUAL AND PROCEDURAL HISTORY

         In 2005, plaintiff Michael W. Smith purchased an MTD Yard Machine Snow Thrower[2] from a retail store in Anne Arundel County, Maryland. (Compl. ¶¶ 3, 5, ECF No. 3)..On January 21, 2016, while Smith was attempting to re-inflate a tire on the snow thrower, the rim of the wheel assembly suddenly exploded, injuring him. (Id. ¶ 6).

         MTD designed and manufactured the snow thrower and its component parts, including the wheel assembly. (Id. ¶ 7; Defs.' Mot. at 2-3, ECF No. 44-1). On December 31, 2018, Smith filed suit against MTD in the Circuit Court for Anne Arundel County, alleging strict liability for a defective product, negligence, breach of the implied warranty of merchantability, and breach of the implied warranty of fitness for a particular purpose. (Compl. ¶¶ 10-23, ECF No. 3). MTD removed the case to this court, claiming diversity jurisdiction under 28 U.S.C. § 1332. (Defs.' Notice of Removal at 2, ECF No. I).[3]

         The parties and events relevant to this case span several states and two countries. MTD's various entities maintain headquarters and principal places of business in Ohio[4] and Smith is a lifelong resident of Maryland. According to the Vice President of Product Safety & Compliance for MTD Products Inc., Daniel J. Martens, the plastic wheel rims on the snow thrower were designed, manufactured, and tested in Ohio, and the plastic wheel rims were assembled onto the snow thrower at a facility in Canada. (Martens Aff. ¶¶ 9-11, Defs.' Mot. Ex. A, ECF No. 44-3). MTD further states that the snow thrower bearing the model and serial number alleged by Smith was sold and shipped to a Home Depot store in New Jersey. (Id. ¶ 14). It is undisputed that Smith's injuries occurred in Maryland. (Defs.' Mot. at 4, ECF No. 44-1).

         MTD filed a motion for summary judgment, arguing that the court should apply Ohio law and find that Smith's claims are barred by Ohio's ten-year statute of repose for product liability actions. The motion has been fully briefed, and no oral argument is necessary.

         STANDARD OF REVIEW

         Federal Rule of Civil Procedure 56(a) provides that summary judgment should be granted "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed.R.Civ.P. 56(a). "A dispute is genuine if 'a reasonable jury could return a verdict for the nonmoving party.'" Libertarian Party of Va. v. Judd, 718 F.3d 308, 313 (4th Cir. 2013) (quoting Dulaney v. Packaging Corp. of Am., 613 F.3d 323, 330 (4th Cir. 2012)). "A fact is material if it 'might affect the outcome of the suit under the governing law. "'Id. (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986)). Accordingly, "the mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment[.]" Anderson, 477 U.S. at 247-48.

         The court must view the evidence in the light most favorable to the nonmoving party, Tolan v. Cotton, 134 S.Ct. 1861, 1866 (2014) (per curiam), and draw all reasonable inferences in that party's favor, Scott v. Harris, 550 U.S. 372, 378 (2007) (citations omitted); see also Jacobs v. N.C. Admin. Office of the Courts, 780 F.3d 562, 568-69 (4th Cir. 2015). At the same time, the court must "prevent factually unsupported claims and defenses from proceeding to trial." Bouchat v. Balt. Ravens Football Club, Inc., 346 F.3d 514, 526 (4th Cir. 2003) (quoting Drewitt v. Pratt, 999 F.2d 774, 778-79 (4th Cir. 1993)).

         ANALYSIS

         A. Choice of Law

         i. Lex Loci Delicti

         Federal courts sitting in diversity must apply the substantive law of the forum state, including the forum state's choice of law rules. Klaxon Co. v. Stentor Elect. Mfg. Co.,313 U.S. 487, 496-97 (1941); Colgan Air, Inc. v. Raytheon Aircraft Co.,507 F.3d 270, 275 (4th Cir. 2007). For claims in tort, Maryland follows the lex loci delicti rule. Proctor v. Washington Metro. Area Transit Auth.,412 Md. 691, 726 (2010) (citing Philip Morris v. Angeletti,358 Md. 689, 744 (2000)). The lex loci delicti rule provides that "the substantive tort law of the state where the wrong occur[s]" governs. Philip Morris, 358 Md. at 746 (quoting Hauch v. Connor,295 Md. 120, 123 (1983). "[W]here the events giving rise to a tort action occur in more than one State," the court must "apply the law of the ...


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