Smith v. China Manufacturers Alliance L L C, 2:19-cv-01111

This case arises from a 2018 motor vehicle accident in Louisiana involving a dump truck driven by Billy Smith, outfitted with "Double Coin" tires manufactured by Shanghai Huayi Group (SHG) and distributed by China Manufacturers Alliance (CMA).
The complaint alleges that a catastrophic tread/belt separation in the tires caused the truck to overturn, leading to severe injuries to Smith.
Smith filed suit for negligent design, manufacture, and distribution under Louisiana Civil Code article 2315, with the action removed to federal court under diversity jurisdiction.
After Smith's death in 2021, his spouse and children were substituted as plaintiffs, turning the matter into a survival action; they later sought and were denied the opportunity to add a wrongful death claim.
Defendants filed a motion in limine to exclude evidence of Smith's cause of death, arguing such evidence is irrelevant and prejudicial in the absence of a wrongful death claim.
The plaintiffs contend the cause of death remains relevant to prove damages for lost earning capacity and suffering in the survival action.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of evidence of Smith’s cause of death	Cause of death is relevant to survival damages and loss of earning capacity	Evidence of death is irrelevant and prejudicial absent wrongful death claim	Evidence of cause of death is admissible as relevant to damages

Taylor v. Giddens, 618 So.2d 834 (La. 1993) (Defining scope of survival actions under Louisiana law)
White v. Entergy Gulf States La., LLC, 167 So.3d 764 (La. Ct. App. 1st Cir. 2014) (Clarifying survival action damages)