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Brooks v. GAF Materials Corp.

Citations: 41 F. Supp. 3d 474; 2014 WL 3349906; 2014 U.S. Dist. LEXIS 93055Docket: Civil Action No. 8:11-cv-00983-JMC

Court: District Court, D. South Carolina; July 9, 2014; Federal District Court

Narrative Opinion Summary

In this class action lawsuit, the plaintiffs, represented by Jack and Ellen Brooks, allege that GAF Materials Corporation manufactured defective Timberline® roofing shingles. The plaintiffs assert claims of negligence, negligent misrepresentation, breach of express and implied warranties, fraud, unjust enrichment, and violations of the South Carolina Unfair Trade Practices Act (SCUTPA). GAF moved for summary judgment on these claims, arguing, among other points, that the plaintiffs were bound by a limited warranty and that no additional warranties existed. The court granted summary judgment for GAF on certain claims, including negligent misrepresentation and SCUTPA, due to insufficient evidence from the plaintiffs. However, GAF's motion was denied regarding other class claims, such as negligence and breach of express and implied warranties, as there were genuine disputes of material fact. The court also allows the plaintiffs to pursue unjust enrichment as an alternative remedy. While the Named Plaintiffs’ claims were dismissed, the court permits the continuation of the class action with a substitution of a new class representative. The case will proceed to trial on the remaining class claims.

Legal Issues Addressed

Breach of Express Warranty under South Carolina Law

Application: The court determines that a genuine issue of material fact exists regarding whether GAF established an express warranty concerning the Timberline® 30 shingles' expected duration.

Reasoning: The court finds sufficient evidence to create a genuine issue of material fact regarding whether GAF established an express warranty concerning the Timberline® 30 shingles' expected duration.

Negligence Claims in Product Liability

Application: The court is inclined to deny GAF's summary judgment motion concerning the negligence claim, as proximate cause and breach of duty are factual questions.

Reasoning: Consequently, the court is inclined to deny GAF's summary judgment motion concerning the negligence claim, as proximate cause and breach of duty are factual questions.

Negligent Misrepresentation Requirements

Application: The court grants GAF's motion for summary judgment on the negligent misrepresentation claim due to insufficient evidence of a false representation or reliance by the Named Plaintiffs.

Reasoning: Consequently, the court finds the Named Plaintiffs lack sufficient facts for a jury to conclude that GAF made a false representation, granting GAF's motion for summary judgment on the negligent misrepresentation claim.

South Carolina Unfair Trade Practices Act (SCUTPA)

Application: The court finds GAF is entitled to summary judgment on the SCUTPA claim due to insufficient evidence of deceptive marketing related to Timberline® shingles.

Reasoning: Consequently, GAF's motion for summary judgment is granted concerning the SCUTPA claim.

Summary Judgment Requirements

Application: The court applies the standard for summary judgment, finding it appropriate when there is no genuine dispute regarding any material fact.

Reasoning: Summary judgment is appropriate when the moving party establishes there is no genuine dispute regarding any material fact, thus entitling them to judgment as a matter of law, per Federal Rule of Civil Procedure 56(a).

Unjust Enrichment as an Alternative Remedy

Application: The court allows the plaintiffs to pursue unjust enrichment as an alternative theory if no remedy is available under other claims.

Reasoning: Plaintiffs can plead alternative claims and are not required to elect remedies until after the verdict. The court, therefore, denies GAF's motion for summary judgment regarding the unjust enrichment claim.