Jones v. Staübli Motor Sports Div. of Staübli Am. Corp.
| Decision Date | 19 September 2012 |
| Docket Number | Cases Nos. 2:09–cv–1120,2:10–cv–0037. |
| Citation | 897 F.Supp.2d 599 |
| Parties | Keith JONES, Plaintiff, v. STAÜBLI MOTOR SPORTS DIVISION OF STAÜBLI AMERICAN CORPORATION, et al., Defendants. and Federal Insurance Company, Plaintiff, v. Stäubli Motor Sports, et al., Defendants. |
| Court | U.S. District Court — Southern District of Ohio |
OPINION TEXT STARTS HERE
John Marshall Alton, John M. Alton Co., LPA, Columbus, OH, Dale H. Eikenberry, Douglas B. King, Matthew J. Trainor, Indianapolis, IN, for Plaintiff.
William B. Benson, Wiles, Boyle, Burkholder & Bringardner Co., LPA, Mark C. Melko, A.J. Hensel, Aaron Todd Brogdon, Kerry Renker Green, Kevin P. Foley, Reminger & Reminger Co., Columbus, David W. Orlandini, David W. Orlandini Davis & Young, LPA, Westerville, OH, for Defendants.
These consolidated cases are before the Court on the motions for summary judgment filed by Defendant Staübli America, Inc., in Case No. 2:09–cv–1120, and Defendants Staübli America, Inc., and Staübli Corporation in Case No. 2:10–cv–37 (collectively, “Staübli”). (ECF No. 120 in Case No. 2:09–cv–1120 and ECF No. 106 in Case No. 2:10–cv–37.) Also before the Court are the memoranda in opposition to summary judgment of Plaintiff Keith Jones (ECF No. 142 in 2:09–cv–1120) and Plaintiff Federal Insurance Company (ECF No. 116 in Case No. 2:10–cv–37), and Staübli's reply memoranda (ECF No. 156 in 2:09–cv–1120 and ECF No. 120 in Case No. 2:10–cv–37). For the reasons that follow, the motions for summary judgment are GRANTED IN PART AND DENIED IN PART. Though the Court finds that Staübli is entitled to summary judgment on some of the claims asserted in the Plaintiffs' complaints, there are genuine issues of material fact that preclude summary judgment on product liability claims brought under the Ohio Product Liability Act.
This case arises from an accident that occurred on July 19, 2008, in the pit area of the Mid–Ohio Racetrack during an American LeMans Racing Series race. Plaintiff Keith Jones worked as a refueler for the pit crew of the de Ferran Motorsports racing team. Thinking that the refueling process was complete during a fuel-only pit stop during the race, the pit crew chief implored the de Ferran Motorsports driver to pull out of the pit area and rejoin the race. Unfortunately, at the time the car pulled away, Jones had not yet disconnected the fuel probe from the car. The fuel hose broke and spilled fuel, which ignited into a fire that severely injured Jones. Jones contends that the fueling system manufactured by Defendant Staübli was defective.
In the early 2000s, Defendant Staübli designed a two-part fueling system, dubbed the Staübli Advanced Filling (“SAF”) system, for use in auto racing. The main goal of the SAF was to prevent fuel spillage and therefore reduce the risk of fire during the refueling process. The SAF consists of (1) the socket, which is attached to a fuel probe and hose that in turn connects to the fuel source, and (2) the plug (also called the “buckeye” in racing parlance), which is attached to the car. Staübli obtained a patent for the SAF and began marketing the system in 2003. Today, the SAF is used by racing teams in various auto racing series around the world.
To operate the SAF, the fueler holds the socket by its two handles and connects it to the plug on the car. The fueler then pushes down on the handles, causing the socket to lock onto the plug, which in turn allows fuel to flow into the car. The SAF is designed such that the sequencing of the operation prevents fuel leaks. The SAF is also designed to make it easy for the fueler to decouple the socket from the plug once the fueling process is complete.
To remove the socket when the fueling is complete, the fueler must simply release pressure on the handles. As the SAF system is designed, releasing the handles stops the flow of fuel and also disconnects the socket from the plug. The ease of disconnecting the socket from the plug is a key safety feature of the SAF: the handles of the socket have springs in them that help push the socket off the plug when the fueler releases the handles. Thus, when refueling is complete during a pit stop, the fueler can simply guide the fuel hose away from the car as the SAF socket releases itself.
In marketing literature, Staübli described the SAF as featuring a “[s]afe and reliable connection” and being “easy to operate.” The literature also touted a “ ‘dead man principle’ function” that allowed easy release when the handles were released. Staübli also touted that its socket design “prevents any jamming during connection to or disconnection from the plug.” There is testimony in the record indicating that race pit crew teams relied upon the quick disconnect feature of the SAF, such that they timed the restart of the race car after refueling based upon the movement of the fueler away from the car.
On July 19, 2008, Jones was the refueler for the de Ferran Motorsports pit crew during an American LeMans Racing Series race at the Mid–Ohio Raceway. When the de Ferran Motorsports car came in for a refueling stop, Jones attached the SAF socket to the plug with two hands to begin the refueling process. After coupling the socket and plug, Jones removed his left hand from the handle and held down only the socket's right handle; with his left hand, Jones held the fuel hose in a raised position. (Jones Dep. 170–171, ECF No. 105.) 1 Jones testified at his deposition that he refueled the car this way ( i.e. holding the socket with one hand and the hose with the other) to remove “sag” from the hose and increase the speed of the fuel flow. ( Id. at 171.) A Staübli engineer testified that operating the SAF in this manner should not have affected the ease of disengaging the socket from the plug once the fueling was complete. (Tiberghien Dep. 63, ECF No. 115.)
When he was finished refueling the car, Jones released the pressure on the socket handle in order to release the socket. But on this occasion, the socket did not disconnect from the plug. Jones then placed his left hand on the left handle and tried to remove the socket using both hands. Again, however, the socket did not disconnect. Thus, after two attempts to disconnect, the SAF socket (and therefore the fuel hose) remained connected to the race car.
Unfortunately for Jones, his body turned away from the car during one of his attempts to disconnect the SAF socket from the plug. Based on this movement, pit crew chief John Anderson signaled the driver to go and pit crew member Steve Regan followed suit by lifting the “lollipop” stop sign that he held in front of the driver. The driver pulled forward with the fuel hose still attached to the car. As a result, the hose broke, causing fuel to spill onto Jones. Heat from the car's exhaust ignited the fuel, setting Jones on fire. Another de Ferran Motorsports crew member and members of other race teams extinguished the fire, but not before Jones suffered third-degree burns to his hands, forearms, face, head, legs, and feet.
At the time of the accident, Jones was wearing a fire-resistant jacket and fire-resistant pants that protected his torso from the fire. Jones was also wearing a balaclava (a cloth headgear resembling a ski mask) and helmet to protect his head and face. Jones did not, however, wear fire-resistant shoes or gloves even though they were provided to him by de Ferran Motorsports. According to Jones, the fire-resistant shoes fit poorly due to the width of his feet and the fire-resistant gloves were too bulky such that they gave Jones “an unsafe feeling for the handles on the fuel probe.” (Jones Dep. 129, ECF No. 104.) Instead of fire-resistant shoes and gloves, Jones wore ordinary tennis shoes and a “regular pair of Mechanix Wear gloves” on the day of the race. ( Id. at 130.)
After learning of the accident that injured Jones, Staübli asked de Ferran Motorsports if it would return the subject SAF for inspection. de Ferran Motorsports agreed and gave the SAF to a Staübli representative. The SAF was eventually shipped to Staübli's facility in Faverges, France for inspection. Staübli's Quality Department in Faverges inspected the SAF and prepared a written report, which concluded that it was “impossible” to determine the cause of the disconnection failure experienced by Jones at the time of the accident. After inspection, the SAF parts were stored on a shelf in the “After Sales Department” of the Staübli facility in Faverges, France. (Mayeur Dep. 12–15, ECF No. 152.) At some unknown time, however, the SAF parts were discarded. As a result, the SAF that failed at the time of the accident in this case is not available for Plaintiffs' inspection, nor is it available to be introduced as evidence in this case.
Despite being unable to determine why the SAF did not disconnect for Jones at the time of the accident, Staübli representatives familiar with the product acknowledge that a properly functioning SAF socket should have come off easily once Jones released pressure on the handles. For example, Staübli Motorsports Manager Jeff Barrow wrote in an e-mail to de Ferran Motorsports just two days after the fire, (Barrow Dep. Ex. 16, ECF No. 139.) Similarly, Alain–Christophe Tiberghien, an engineer and the head of Staübli's connectors research and development department, testified at a Fed.R.Civ.P. 30(b)(6) deposition that the SAF did not operate as designed or intended at the time of the accident: the SAF socket should have released from the plug. (Tiberghien Dep. 60–61, 102–105, ECF No. 115.)
Jones commenced the lawsuit in Case No. 2:09–cv–1120 in December 2009. Jones's Amended Complaint named Staübli Motor Division of Staübli America...
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