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581 F.Supp.3d 912
E.D. Mich.
2022
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Background:

  • On November 3, 2018, Jill Klein was killed when a Caterpillar 785B mining hauler crushed her parked pickup at a Carmeuse quarry in Michigan.
  • In 2015 Carmeuse purchased a Caterpillar Certified Rebuild/Certified Rebuild Upgrade performed by FABCO CAT pursuant to Caterpillar technical manuals.
  • Brent Klein (personal representative) sued Caterpillar alleging negligent repair/modification and products-liability (design defect) claims; pleadings were amended multiple times and Klein sought leave to file a Third Amended Complaint clarifying theories.
  • Caterpillar moved to dismiss, arguing (1) Michigan law imposes no duty to retrofit/modify and (2) FABCO CAT—not Caterpillar—performed the rebuild, so Caterpillar owed no duty.
  • The court found Klein plausibly alleged (a) a voluntary-assumption-of-duty theory for negligent repair/modification and factual questions about agency between Caterpillar and FABCO CAT, and (b) a plausible negligent-design alternative (bumper, obstacle detection, improved cab visibility, audible warnings).
  • The court granted leave to amend and denied Caterpillar’s motion to dismiss, allowing the negligence and products-liability claims to proceed.

Issues:

Issue Klein's Argument Caterpillar's Argument Held
Leave to amend under Rule 15 Grant leave; Third Amended Complaint clarifies existing allegations and was timely Opposition arguing futility Granted — no undue delay, prejudice, or futility shown
Effect of amendment on pending motion to dismiss Court may consider the motion as to the amended pleading Motion to dismiss original complaint; Caterpillar sought dismissal Court treated motion as directed to Third Amended Complaint (amendment largely identical)
Duty for negligent repair/modification Caterpillar voluntarily performed or controlled the rebuild and thus assumed a duty to perform nonnegligently; agency for FABCO CAT is a factual issue No duty because Michigan recognizes no affirmative duty to modify; FABCO CAT (not Caterpillar) performed and was independent Denied dismissal — voluntary-assumption-of-duty alleged and agency/actual control is a question of fact
Products-liability (negligent design) pleading sufficiency Alleges feasible safer alternatives (full front bumper, obstacle detection, improved cab visibility, audible warnings) that would have prevented death Design-defect theory insufficient as plead or barred as duty-to-modify claim Denied dismissal — negligent-design claim plausibly alleged under Michigan law

Key Cases Cited

  • Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading requires more than labels and conclusions)
  • Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint must state a plausible claim for relief)
  • Foman v. Davis, 371 U.S. 178 (1962) (Rule 15 leave to amend should be freely given absent limiting factors)
  • Klaxon Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487 (1941) (apply forum state substantive law in diversity cases)
  • Leone v. BMI Refractory Servs., Inc., 893 F.3d 359 (6th Cir. 2018) (Michigan recognizes voluntary-assumption-of-duty doctrine)
  • Gregory v. Cincinnati Inc., 538 N.W.2d 325 (Mich. 1995) (framework for negligent-design/risk-utility analysis)
  • Prentis v. Yale Mfg., 365 N.W.2d 176 (Mich. 1984) (risk-utility test for design defects)
  • Meretta v. Peach, 491 N.W.2d 278 (Mich. Ct. App. 1992) (disputed agency questions create factual issues for the jury)
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Case Details

Case Name: Klein, by her Personal Representative, Brent Klein v. Caterpillar Inc
Court Name: District Court, E.D. Michigan
Date Published: Jan 12, 2022
Citations: 581 F.Supp.3d 912; 1:21-cv-11748
Docket Number: 1:21-cv-11748
Court Abbreviation: E.D. Mich.
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