Eberhart v. Amazon.com, Inc.
325 F. Supp. 3d 393
S.D. Ill.2018Background
- Plaintiff Jacob T. Eberhart purchased a CoffeeGet French-press coffeemaker on Amazon.com and was injured when the glass pot allegedly shattered while he was washing it.
- Eberhart sued Amazon asserting alternative theories: strict products liability, negligence, vicarious liability, breach of express warranty, and misrepresentation.
- Amazon did not manufacture or design the coffeemaker; evidence shows the product was sold by third‑party seller "CoffeeGet," which participated in Amazon's Fulfillment by Amazon (FBA) program and retained title to inventory.
- Amazon provided the marketplace, optional FBA warehousing/shipping services, and payment processing; it did not write the product detail page or take title to the coffeemaker.
- The core legal question was whether an online marketplace like Amazon is a "seller" or part of the distribution chain such that it can be held strictly liable (and liable on related negligence/warranty/representation theories) under New York law.
- The court granted Amazon summary judgment, concluding Amazon was not within the product's chain of distribution and owed no duty or made no statements supporting the remaining claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Amazon is strictly liable as a "seller/distributor" for a defective product sold by a third party on its marketplace | Amazon sold the coffeemaker (or is otherwise liable for third‑party sales) and so can be held strictly liable | Amazon is only a marketplace and logistics provider; it did not manufacture, take title to, or otherwise place the product into the stream of commerce | Amazon is not within the distribution chain and thus not strictly liable; summary judgment for Amazon |
| Whether Amazon owed a common‑law negligence duty regarding the coffeemaker | Eberhart asserts negligence based on Amazon's role in the transaction | Amazon did not design, manufacture, sell, or distribute the product to Eberhart and thus owed no duty | No duty found; negligence claims dismissed |
| Whether Amazon can be liable for breach of express warranty | Amazon made representations about the product or is vicariously liable for seller statements | Amazon did not make any statements or warranties about the coffeemaker | Breach of warranty claim fails; summary judgment for Amazon |
| Whether Amazon can be liable for misrepresentation based on product listing content | Amazon is responsible for content and can be held for misrepresentations | Product content was provided by third party; §230 and lack of Amazon authorship preclude liability | Misrepresentation claim fails; summary judgment for Amazon |
Key Cases Cited
- Finerty v. Abex Corp., 27 N.Y.3d 236 (discusses strict liability limited to manufacturers/actors within distribution chain)
- Sukljian v. Charles Ross & Son Co., 69 N.Y.2d 89 (extended strict liability to certain sellers/distributors in distribution chain)
- West v. Am. Tel. & Tel. Co., 311 U.S. 223 (guidance on predicting state law decisions in federal diversity cases)
- Hoover v. New Holland N. Am., Inc., 23 N.Y.3d 41 (chain‑of‑distribution requirement for products liability)
- Heller v. U.S. Suzuki Motor Corp., 64 N.Y.2d 407 (recognition that strict products liability reaches manufacturers and those in the distributive chain)