James Blasius v. Angel Automotive Inc.
2016 U.S. App. LEXIS 18390
| 7th Cir. | 2016Background
- Blasius hired Angel Automotive, Inc. (AAI) in June 2012 to perform extensive upgrades and replacements on his 2005 Ford Excursion, including fuel-system work; AAI removed the body and disconnected/reconnected multiple fluid lines.
- AAI completed work and returned the vehicle to Blasius on June 28, 2012; Blasius drove ~200 miles and reported performance issues to AAI the next day.
- On June 29, 2012, while towing a trailer, the Excursion emitted smoke, brakes failed, diesel fuel was observed running along the vehicle, and the vehicle subsequently burned and was destroyed.
- Blasius’s expert (Adam Hooker) inspected remnants and opined that a leak in a fluid system (fuel or brake fluid), interacting with an exposed/unguarded exhaust, was the most likely cause; AAI’s owner also conceded a fuel leak may have caused the fire.
- The district court granted summary judgment for AAI, finding insufficient evidence of proximate cause and rejecting res ipsa loquitur; the Seventh Circuit reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proximate cause — causation in fact | Blasius: expert opinion and contemporaneous observations support that AAI’s disassembly/reassembly caused a fluid leak that ignited on exhaust | AAI: evidence is speculative, expert testimony equivocal, lacks proof "more likely than not" | Reversed: a reasonable jury could find causation from Hooker’s report, deposition, Blasius’s observations, and AAI admission |
| Sufficiency of expert evidence at summary judgment | Hooker’s report and testimony provide a specific, consistent theory tying AAI’s manipulations to a leak and fire | AAI: Hooker conceded uncertainty and resisted legal phrasing of "more likely than not" so evidence is too speculative | Reversed: expert need only create a triable issue at summary judgment, not prove causation conclusively |
| Res ipsa loquitur — exclusive control | Blasius: AAI was the last and only party to perform maintenance and thus had control over the likely causes | AAI: Blasius had the vehicle when it burned, so AAI lacked exclusive control | Reversed: control in res ipsa is expansive; defendant need not have physical control at the moment if it was last to manipulate probable causes |
| Res ipsa loquitur — accident type (ordinariness) | Blasius: relatively new/overhauled vehicle fires of this kind are not ordinary and suggest negligence | AAI: many ordinary causes (wear, road hazards) could explain leaks/fires | Reversed: court finds such a post-repair vehicle fire is not ordinary and res ipsa’s second prong is satisfied |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard and jury inference threshold)
- Newell v. Westinghouse Elec. Corp., 36 F.3d 576 (res ipsa control and "last person to service" analysis)
- Maroules v. Jumbo, Inc., 452 F.3d 639 (elements and effect of res ipsa loquitur)
- City of Gary ex rel. King v. Smith & Wesson Corp., 801 N.E.2d 1222 (proximate cause framework under Indiana law)
- Kincade v. Mac Corp., 773 N.E.2d 909 (illustrative summary judgment dismissal when plaintiff’s theories are speculative or misdirected)