Gerald Johnson & Laurel Johnson v. The Toro Company & Sunbelt Rentals, Inc.

Summary

The United States District Court for the Middle District of Tennessee denied Sunbelt Rentals, Inc.’s motion to dismiss in a products-liability action arising from injuries sustained when a rented Toro compact utility loader overturned. The court held that the plaintiffs plausibly alleged exceptions to the Tennessee Products Liability Act’s seller immunity, based on Sunbelt’s alleged control over equipment instructions and warnings and its alteration or inadequate maintenance of the loader’s safety information. The court did not resolve the parties’ broader dispute over which claims fall within the Tennessee Products Liability Act.

Holdings

1. The complaint plausibly alleged that Sunbelt exercised substantial control over the equipment's instructions and warnings, including the paper manual and QR-code-linked digital materials, so the substantial-control exception to seller immunity could apply.
2. The complaint plausibly alleged that Sunbelt altered or modified the loader by leaving a deteriorated manual in an inadequate storage canister and that the alleged modification was a substantial factor in causing Johnson's injuries.
3. Sunbelt's motion to dismiss was denied because the First Amended Complaint plausibly alleged facts establishing at least one, and potentially both, exceptions to seller immunity.

Questions Presented

1. Whether the First Amended Complaint plausibly alleged that Sunbelt exercised substantial control over the design, packaging, or labeling aspect of the equipment that allegedly caused the injury, within the exception to seller immunity under Tennessee Code Annotated section 29-28-106(1).
2. Whether the First Amended Complaint plausibly alleged that Sunbelt altered or modified the loader and that the alteration or modification was a substantial factor in causing the injury, within section 29-28-106(2).
3. Whether Sunbelt was entitled to dismissal under Rule 12(b)(6) based on seller immunity under the Tennessee Products Liability Act.

Disposition

other