Bennett v. Millercoors, LLC
838 F. Supp. 2d 470
M.D. La.2011Background
- Plaintiff Leonard Bennett sued MillerCoors for injuries from bottles falling out of a corrugated fiberboard box while loading cases onto a pallet.
- Plaintiff alleged the box was unreasonably dangerous in design and construction and contained inadequate warnings.
- Hartford Insurance Company and Crescent Crown Distributing intervened to recover workers’ compensation benefits paid to Bennett.
- Defendants moved for summary judgment; Bennett did not oppose and conceded no triable facts under the Louisiana Products Liability Act (LPLA).
- The court analyzes under the LPLA, which provides four theories for unreasonableness: construction, design, failure to warn, and nonconformity to an express warranty.
- The court granted summary judgment, dismissing all claims against MillerCoors and dismissing the intervenors’ claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| whether plaintiff can prove unreasonableness under LPLA | Bennett (plaintiff) argues box was unreasonably dangerous in design/construction or warnings. | MillerCoors contends no proof supports unreasonableness under LPLA. | No genuine issue; LPLA claims fail as to construction and design. |
| construction defect standard under LPLA | Box deviated from standards, rendering it unreasonably dangerous. | No evidence of deviation from MillerCoors’ specifications or industry standards. | Construction claim dismissed. |
| design defect and existence of alternative design | There existed an alternative design to prevent injury. | No evidence of an alternative design provided by plaintiff. | Design claim dismissed. |
| warning duty under LPLA | Box lacked adequate warnings to users. | User was sophisticated; no duty to warn to Bennett. | Warning claim dismissed. |
| res ipsa loquitor applicability | Res ipsa could establish negligence. | No exclusive control by MillerCoors; elements not satisfied. | Res ipsa claim dismissed. |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (summary judgment standard; burden shifting)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (genuine issue of material fact required)
- Grimes v. Tex. Dep’t of Mental Health, 102 F.3d 137 (5th Cir. 1996) (sufficiency of evidence; conclusory allegations insufficient)
- Goins v. Galion Mfg. Co., 626 So.2d 1200 (La.App. 3d Cir.1993) (duty to warn; sophistication of user)
- Batiste v. Gen. Motors Corp., 802 So.2d 686 (La.App. 4th Cir.2001) (res ipsa loquitor elements; exclusive control)