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Rodriguez v. GEN. DYNAMICS ARMAMENT & TECH. PRODS.

Citation: 696 F. Supp. 2d 1163Docket: Civil No. 08-00189 SOM/BMK

Court: District Court, D. Hawaii; March 10, 2010; Federal District Court

Narrative Opinion Summary

In this case, plaintiffs filed negligence and strict liability claims against General Dynamics Armament and Technical Products, Inc. (GDATP) following a premature explosion of a mortar cartridge during a U.S. Army training exercise, resulting in one fatality and several injuries. Plaintiffs alleged a manufacturing defect in the cartridge, which was manufactured in 1982, failing to meet government specifications. GDATP filed motions for summary judgment, arguing the absence of a proven defect and invoking defenses such as the government contractor defense, combatant activities exception, and political question doctrine. The court denied GDATP's motions for summary judgment on the negligence and strict liability claims due to unresolved factual issues, particularly regarding compliance with government specifications. However, the court granted summary judgment on the res ipsa loquitur claims, ruling them as non-independent but allowed their use in supporting negligence and strict liability claims. Moreover, the court found expert testimony from John Nixon admissible under Daubert standards, despite GDATP's objections. The court also dismissed GDATP's defenses based on the government contractor and combatant activities exceptions, as well as the political question doctrine, due to a lack of applicability under the case's circumstances. The case will proceed to trial, focusing on the claims of manufacturing defects in the mortar cartridge.

Legal Issues Addressed

Combatant Activities Exception

Application: The court rejected GDATP's attempt to invoke the combatant activities exception, as the case does not involve actual combat conditions.

Reasoning: The Ninth Circuit's justifications for the combatant activities exception are not applicable in this case.

Expert Testimony Admissibility

Application: The court found John Nixon's opinions admissible under Daubert, emphasizing potential reliability and relevance despite GDATP's challenges.

Reasoning: The court ruled Nixon's opinions admissible, passing the Daubert requirements, and stated they would be subjected to rigorous cross-examination.

Government Contractor Defense

Application: GDATP is not entitled to summary judgment under the government contractor defense due to factual disputes regarding compliance with government specifications.

Reasoning: The court finds that GDATP is not entitled to summary judgment on these grounds due to factual disputes regarding compliance with government specifications in the mortar cartridge's manufacture.

Negligence and Strict Liability Claims

Application: The court denied GDATP's motions for summary judgment regarding negligence and strict liability due to existing factual questions.

Reasoning: The court denies GDATP's motion for summary judgment regarding negligence and strict liability claims, while granting it for res ipsa loquitur claims without limiting the doctrine's application to the other claims.

Political Question Doctrine

Application: The court dismissed GDATP's argument that the case involves a nonjusticiable political question, focusing instead on the contractor's performance.

Reasoning: The court rejects GDATP's argument that the case involves a nonjusticiable political question, noting that there is no precedent from the Ninth Circuit regarding soldiers' tort claims against military contractors.

Res Ipsa Loquitur Doctrine

Application: Plaintiffs cannot pursue independent res ipsa loquitur claims but may use the doctrine to support their negligence and strict liability claims during trial.

Reasoning: Plaintiffs are not permitted to pursue independent res ipsa loquitur claims but can utilize the doctrine to support their negligence and strict liability claims during trial.