Products Liability Law Reporter

A federal district court held that a third-party defendant was not liable to the estate of a man killed in a collision between two Freightliners.

Daimler Trucks North America, LLC, designed and manufactured a Freightliner box truck, which was purchased by Houston Freightliner, Inc. (HFI) and sold to Aman Expedite, LLC. After the sale, Aman Expedite contracted with a third party to construct a sleeper berth in the back of the Freightliner, just behind the passenger safety compartment. The following year, Dmytro Pronin was riding in the sleeping berth of the Freightliner, which another driver was operating on a Colorado highway. The driver allegedly swerved while attempting to change lanes and was unable to avoid hitting a semi-truck. Although the passenger safety compartment remained intact, the sleeper berth was destroyed in the crash. Pronin suffered fatal injuries.

His estate brought direct and third-party claims against multiple parties, including HFI. The plaintiff asserted that the Freightliner was defective because HFI failed to equip the truck with forward collision warning, automatic emergency braking, and active brake assist technologies. The defendant knew or should have known of the benefit and effectiveness of this technology, the plaintiff argued, yet chose not to have the technology installed on the freightliner. Moreover, the plaintiff alleged that Pronin’s death resulted from the shoddily constructed sleeper berth. HFI moved to dismiss on the basis that the plaintiff had failed to plausibly allege that a product it designed, manufactured, or sold was the proximate cause of Pronin’s death.

Granting the motion, the district court noted that the Washington Products Liability Act is the exclusive remedy for products liability claims under Washington law. Under the statute, a manufacturer may be liable for the construction or negligent design of a product if it is not reasonably safe when it left the manufacturer’s control and it was the proximate cause of the plaintiff’s injury. The court added that in situations where a component of a whole product can be identified as the cause of the plaintiff’s injury, the component, rather than the product as a whole, is the relevant product for purposes of the statute.

The court found that based on the estate’s allegations, the relevant product that caused Pronin’s injuries was the aftermarket sleeper berth that was added to the truck after it left HFI’s control—not the Freightliner itself. Thus, the court concluded, because HFI did not manufacture or install the sleeper berth, it is not liable for Pronin’s injuries. The court nevertheless allowed the plaintiff to file an amended complaint against HFI.

Citation: United Fin. Cas. Co. v. Aman Expedite, LLC, 2024 WL 4122262 (W.D. Wash. Sept. 9, 2024).