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Heneghan v. Crown Crafts Infant Products, Inc.

Citations: 868 F. Supp. 2d 1153; 2012 U.S. Dist. LEXIS 52528; 2012 WL 1309174Docket: Case No. C10-05908RJB

Court: District Court, W.D. Washington; April 13, 2012; Federal District Court

Narrative Opinion Summary

The case involves a wrongful death claim under the Washington Product Liability Act (WPLA) following the tragic death of an infant who was placed in a Nojo sling. The plaintiffs, including the child's parents, filed suit against Crown Crafts, the manufacturer of the sling, and later added Dr. William Sears, a pediatrician and author, due to his endorsement of 'babywearing' and involvement with the sling's promotion. Dr. Sears moved for summary judgment, asserting he was not a product seller as defined by the WPLA and had no direct involvement in the marketing or sale of the sling. The court denied the motion, holding that genuine issues of material fact existed regarding Dr. Sears' potential liability as a product seller or manufacturer, given his promotional activities and licensing agreement. The ruling emphasized that the trier of fact must resolve whether Dr. Sears' actions amounted to negligent misrepresentation or breach of warranty. Consequently, the case will proceed to trial to determine Dr. Sears' liability under the WPLA.

Legal Issues Addressed

Definition of a Product Seller under Washington Product Liability Act

Application: The court considered whether Dr. Sears could be classified as a 'product seller' under the WPLA due to his involvement in the promotion and sale of the Nojo sling.

Reasoning: The WPLA defines a 'product seller' as any entity engaged in selling products, including manufacturers, wholesalers, distributors, and retailers.

Negligent Misrepresentation and Product Liability

Application: Plaintiffs alleged that Dr. Sears made false and misleading representations about the Nojo sling, which could hold him liable under the WPLA even if he did not sell the product directly.

Reasoning: Plaintiffs argue that genuine issues of fact exist regarding Dr. Sears’ involvement in the sling's design, marketing, and promotion through his writings and website.

Role of Trier of Fact in Determining Product Seller Status

Application: The court determined that the issue of whether Dr. Sears qualifies as a product seller or manufacturer under the WPLA is a question for the trier of fact.

Reasoning: This connection necessitates a determination by the trier of fact regarding whether Dr. Sears qualifies as a product seller or manufacturer.

Summary Judgment Standard

Application: The court applied the standard that summary judgment is appropriate only when there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law.

Reasoning: The excerpt also outlines the standard for summary judgment, which requires no genuine issue of material fact and entitlement to judgment as a matter of law.