Block v. Toyota Motor Corp.
2011 U.S. App. LEXIS 25081
| 8th Cir. | 2011Background
- Block sued Brooklyn Park Motors and Toyota affiliates in Minnesota state court for strict products liability, negligence, and fraud after a 2006 crash involving a 1996 Toyota Camry; suit later removed to federal court.
- District court held Brooklyn Park Motors was fraudulently joined, denied remand, and dismissed claims against Brooklyn Park Motors with prejudice under Minnesota seller's exception statute § 544.41.
- Block sought reconsideration; district court denied; final judgment entered in favor of Brooklyn Park Motors.
- Block appeals, arguing no fraudulent joinder and that dismissal with prejudice was improper.
- Court reviews removal de novo and addresses whether there is a reasonable basis for claims against Brooklyn Park Motors under Minnesota law and the fraudulent joinder standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Brooklyn Park Motors fraudulently joined | Block argues no reasonable basis to join Brooklyn Park Motors. | Toyota defendants contend Brooklyn Park Motors is fraudulently joined to defeat removal. | Yes; fraudulent joinder established; removal proper and Brooklyn Park Motors dismissed. |
| Does Minn. Stat. § 544.41 preclude fraudulent joinder | Seller's exception could create a viable strict liability claim, negating fraudulent joinder. | Statute does not require reinstatement pre-removal and cannot defeat removal. | No; seller's exception does not preclude finding fraudulent joinder in this context. |
| Was there a reasonable basis for strict liability against Brooklyn Park Motors | Block alleged actual knowledge of defect and proximate knowledge via NHTSA complaints. | No factual basis Brooklyn Park Motors knew of defect pre-sale; exceptions not shown. | No; no reasonable basis under § 544.41 for strict liability against Brooklyn Park Motors. |
| Was there a reasonable basis for negligence against Brooklyn Park Motors | Brooklyn Park Motors failed to warn despite potential knowledge of defect. | No duty to warn absent knowledge of defect before sale; connection remote; no basis. | No; no reasonable basis for negligence against Brooklyn Park Motors. |
Key Cases Cited
- Filla v. Norfolk S. Ry. Co., 336 F.3d 806 (8th Cir. 2003) (fraudulent joinder requires more than a Rule 12(b)(6) dismissal)
- Junk v. Terminix Int'l Co., 628 F.3d 439 (8th Cir. 2010) (reasonable basis for predicting liability under state law is required)
- Knudson v. Systems Painters, Inc., 634 F.3d 968 (8th Cir. 2011) (de novo review of removal decisions; focus beyond pleadings)
- Masepohl v. Am. Tobacco Co., Inc., 974 F. Supp. 1245 (D. Minn. 1997) (fraudulent joinder considerations in state-law claims against nonmanufacturers)
- In re Prempro Prod. Liab. Litig., 591 F.3d 613 (8th Cir. 2010) (jurisdictional constraints and remand principles in complex litigations)