3rd Circuit Grants En Banc Review of Amazon's Liability for Defective Products Sold by 3rd Parties
An injured user of a dog leash was unable to locate the seller or contact the manufacturer directly, and so she sued Amazon.com, alleging products liability, breach of warranty and duty, and negligence.
August 26, 2019 at 11:55 AM
3 minute read
A ruling by the U.S. Court of Appeals for the Third Circuit last month created a potential split between federal circuits regarding whether the online retail giant Amazon could be held liable for defective products sold by third parties. That split, however, may be short-lived, as the federal appeals court recently agreed to reconsider the case en banc.
On Aug. 23, the appeals court granted Amazon's request to have an expanded panel take a fresh look at Oberdorf v. Amazon. As part of the decision to reconsider the case, the three-judge panel's ruling from last month has been vacated pending further review.
A date has not yet been set for the hearing.
The lawsuit stemmed from an eye injury Heather Oberdorf sustained while walking her dog in early 2015. According to the allegations, she was using a leash she'd purchased a month earlier through Amazon.com from a company called The Furry Gang. After the incident, Oberdorf was unable to locate The Furry Gang or contact the manufacturer directly, and so she sued Amazon.com, alleging products liability, breach of warranty and duty, and negligence.
In early July, the panel on a 2-1 vote reversed a ruling from the U.S. District Court for the Middle District of Pennsylvania, which had predicted that the state Supreme Court would not consider the company to be a "seller" for strict liability purposes.
Amazon had argued that, under the test outlined in a 1989 Pennsylvania Supreme Court decision, it could not be held liable as a "seller," but Senior Judge Jane Richards Roth, who wrote the Third Circuit's majority opinion, determined that because the company was in a position to prevent the circulation of defective products and because imposing liability would incentivize safety that test weighed more in favor of designating the company as a "seller" under 402A of the Second Restatement of Torts.
"Amazon's customers are particularly vulnerable in situations like the present case," Roth said. "Neither the [plaintiffs] nor Amazon has been able to locate the third-party vendor, The Furry Gang. Conversely, had there been an incentive for Amazon to keep track of its third-party vendors, it might have done so."
The ruling bucked a recent trend where both the Fourth and Sixth circuits held that the company could not be liable as a seller under state products liability laws.
In its request to have the initial ruling reconsidered, Amazon contended that the ruling conflicted with other districts and argued the appeal judges had been acting as "judicial pioneers," establishing a precedent with "no practical limit."
"The majority's decision 'substantially widen[s]' the scope of liability for online stores and marketplaces operating in Pennsylvania, including Amazon, eBay, Walmart Marketplace, and smaller businesses like Etsy, Bonanza, and Jet," Amazon said in its petition.
David Wilk of Lepley, Engelman, Yaw & Wilk in Williamsport, Pennsylvania, who represented the plaintiffs, said the decision to review the case en banc was not unexpected, given the significance of the issue. He further noted, after the three-judge panel's ruling came down, a district court in Wisconsin similarly ruled the company could be liable for third-party products.
"I'm more than happy to revisit it," he said. "I think the arguments in our favor have only gotten more compelling."
Perkins Coie attorney Brendan Murphy, who is representing Amazon, declined to comment.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllFederal Judge Allows Elderly Woman's Consumer Protection Suit to Proceed Against Citizens Bank
5 minute readJudge Leaves Statute of Limitations Question in Injury Crash Suit for a Jury
4 minute readSupreme Court's Ruling in 'Students for Fair Admissions' and Its Impact on DEI Initiatives in the Workplace
6 minute readTrending Stories
- 1Phila. Jury Hits Sig Sauer With $11M Verdict Over Alleged Gun Defect
- 2Lost in the Legal Maze: How State Regulations Are Hindering Hemp Operators' Success
- 3New Associates Yearbook 2024
- 4Disbarred Attorney Alleges ADA Violations in Lawsuit Against Miami-Dade Judges
- 5Free Speech Causes a Neighborly Feud
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250