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Scala v. Fedex Freight, Inc.

Citation: 264 F. Supp. 3d 352Docket: CIVIL ACTION NO. 15-13041-RWZ

Court: District Court, D. Massachusetts; September 6, 2017; Federal District Court

Narrative Opinion Summary

This case involves a negligence claim by the plaintiff against FedEx Freight, Inc., following an incident where a chunk of ice allegedly fell from a FedEx tractor-trailer, resulting in serious injuries. The lawsuit, originally filed in Massachusetts Superior Court, was moved to federal court under diversity jurisdiction. The defendant, FedEx Freight, moved for summary judgment on the basis that no FedEx vehicle was involved in the incident. The court evaluated whether a reasonable jury could find that a FedEx vehicle was present at the time of the accident. Key evidence, including GPS data, indicated that no FedEx Freight trucks were in proximity to the accident site. The plaintiff's reliance on hearsay evidence in the form of a letter was deemed inadmissible, and the court found no genuine dispute of material fact regarding the presence of a FedEx vehicle. Additionally, the court reaffirmed that FedEx Freight, as a subsidiary, could not be held liable for the actions of other FedEx Corporation entities. The court granted FedEx Freight's motion for summary judgment, concluding that neither Massachusetts nor Vermont law would alter the outcome, given the lack of evidence linking FedEx Freight to the incident.

Legal Issues Addressed

Duty of Care in Negligence

Application: FedEx Freight would have no duty to Scala if no vehicle was present at the scene, as it could not have contributed to the alleged harm.

Reasoning: In this case, if no FedEx Freight vehicle was present at the incident scene, FedEx Freight had no duty to Scala, as it could not have contributed to the alleged harm.

Hearsay Evidence

Application: The letter from Broadspire Services is inadmissible as hearsay and cannot undermine the summary judgment motion.

Reasoning: However, the letter is considered hearsay as it lacks evidence of the author's authority or acknowledgment by FedEx Freight, rendering it inadmissible in court.

Negligence and the Elements of Duty, Breach, Causation, and Harm

Application: Scala's negligence claim requires proving that FedEx Freight's truck did not have its ice and snow properly removed, which led to the ice falling onto his vehicle.

Reasoning: Scala's negligence claim hinges on proving that the truck did not have its ice and snow properly removed, leading to the ice falling onto his vehicle.

Parent Company Liability for Subsidiaries

Application: Scala's argument for FedEx Freight's liability as a parent company is unsupported, reaffirming that a parent corporation is not liable for its subsidiaries' acts.

Reasoning: Scala’s argument that FedEx Freight should be liable as a parent company for its subsidiary's actions is unsupported, reaffirming the legal principle that a parent corporation is not liable for its subsidiaries' acts.

Summary Judgment Standards

Application: The court grants summary judgment for FedEx Freight, finding that no reasonable jury could conclude a FedEx vehicle was present at the scene.

Reasoning: The court grants FedEx Freight’s Motion for Summary Judgment, stating that the applicable law is determined by the choice-of-law principles of Massachusetts, the forum state.