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Scanlan v. Sunbeam Products, Inc.

United States District Court, W.D. Kentucky, Louisville

May 24, 2018

STEPHEN AND ALEXANDRIA SCANLAN, INDIVIDUALLY AND AS ADMINISTRATORS OF THE ESTATE OF SAWYER SCANLAN PLAINTIFFS
v.
SUNBEAM PRODUCTS, INC. D/B/A JARDEN CONSUMER SOLUTIONS DEFENDANT

          MEMORANDUM OPINION

          CHARLES R. SIMPSON III, SENIOR JUDGE

         I. Introduction

         This case is before the court on Defendant Sunbeam Products, Inc. d/b/a Jarden Consumer Solutions' (hereinafter “Sunbeam”) motion for summary judgment on Plaintiffs Stephen and Alexandria Scanlan's (collectively “the Scanlans”) claims for survival and punitive damages. ECF Nos. 83 and 84. The Scanlans responded. ECF Nos. 93 and 95. Sunbeam subsequently replied. ECF Nos. 104 and 105. Based on the Sixth Circuit Court of Appeals' decision in this case, Sunbeam also moves for leave to supplement its motion for summary judgment on the Scanlans' claim for punitive damages. ECF No. 126. The Scanlans responded. ECF No. 131. These matters are now ripe for review. For the reasons set forth below, Sunbeam's motion for summary judgment on the Scanlans' claim for survival damages will be denied. Sunbeam's motion for leave to supplement, as well as its motion for summary judgment on the Scanlans' claim for punitive damages, will be granted.

         II. Factual Background

         The facts of this case have previously been detailed by this court.

This case arises from the tragic death of two-year-old Sawyer Scanlan from heatstroke. On December 15, 2010, Stephen Scanlan put his son, Sawyer, to bed in his crib at approximately 9:00 p.m. ECF No. 88-3, p. 7. Stephen turned on the Sunbeam Fan-Forced Heater, Model No. SFH111 (“space heater” or “SFH111”) and turned the thermostat dial to mid-range. Id. at 23. He then left the room and shut the door behind him. Id. at 36. Although Sawyer's mother, Alexandria Scanlan, woke up several times during the night to feed Sawyer's infant sister, she did not check on Sawyer because she did not hear any noise coming from his room and assumed he was sleeping. ECF No. 85-4, p. 58.
At approximately 10:00 a.m. the following morning, Alexandria went to Sawyer's room to wake him. Id. at 66-67. When she opened the bedroom door, she felt a burst of hot air and found Sawyer lying in his crib, unresponsive. Id. at 70-71. An EMS official pronounced Sawyer dead at the scene. The medical examiner concluded that “The death of this 2 ½ year-old male child . . . is attributed to heat exposure due to confinement in a small room with an electric space heater.” ECF No. 52-7. (ECF No. 135).

         In December 2011, the Scanlans filed suit against Sunbeam, stating claims for strict liability, negligence, breach of warranty, violations of the Kentucky Consumer Protection Act (KCPA) and the Magnuson-Moss Warranty Act, survival damages, and punitive damages. ECF No. 1-1. Sunbeam moved for summary judgment on all claims. ECF Nos. 81-84. This court granted Sunbeam's motions for summary judgment on the Scanlans' substantive claims, rendering the claims for survival and punitive damages moot. ECF No. 113. The Scanlans subsequently appealed this decision to the Sixth Circuit, which affirmed the summary judgment ruling for the KCPA claim, and reversed the ruling for the strict liability, negligence, breach of warranty, and Moss-Magnuson Warranty Act claims. ECF No. 119. Thus, the Scanlans' claims for survival and punitive damages are again at issue.

         III. Legal Standard

         The trial court shall grant summary judgment in a case “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). The party moving for summary judgment bears the initial burden of “demonstrating that [there is] no genuine issue of material fact.” Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). If the moving party satisfies this burden, the burden then shifts to the nonmoving party to “point to evidence demonstrating that there is a genuine issue of material fact for trial.” Id. at 323 (emphasis added).

         In considering a motion for summary judgment, the court must consider the facts in the light most favorable to the nonmoving party. Scott v. Harris, 550 U.S. 372, 378, 127 S.Ct. 1769, 167 L.Ed.2d 686 (2007). However, the nonmoving party “must do more than simply show that there is some metaphysical doubt as to the material facts.” Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 586, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). There must actually be “evidence on which the jury could reasonably find for the [nonmoving] party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 252, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986).

         IV. Discussion

         Sunbeam moves for summary judgment on the Scanlans' claims for survival damages and punitive damages. These motions will be considered in further detail below.

         A. Motion for Summary Judgment as to the Scanlans' ...


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