Wadsworth v. Walmart Inc
2:23-cv-00118
| D. Wyo. | Feb 28, 2025Background
- Plaintiffs (the Wadsworth family) sued Walmart Inc. and Jetson Electric Bikes, LLC over a house fire allegedly caused by a hoverboard’s battery failure.
- Defendants claimed the fire began in a plastic shed outside the house, potentially due to improperly discarded cigarettes.
- Plaintiffs requested judicial notice of several statutes and scientific standards related to cigarette ignition and consumer safety regulations for imported products.
- The requests included the Wyoming Reduced Cigarette Ignition Propensity Act, ASTM standards, New York fire safety standards for cigarettes, and certain federal regulations on consumer imports.
- Defendants opposed these requests, arguing their lack of relevance and improper use under evidentiary rules.
- The court reviewed the filings under the Federal Rules of Evidence, focusing on the distinction between legislative and adjudicative facts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial notice of cigarette statutes | Court should judicially notice state/federal standards related to cigarettes | Statutes are not adjudicative facts relevant to this case | Denied - not adjudicative, not relevant |
| Judicial notice of consumer safety law | Court should notice CPSC and related federal statutes | No such violations or claims alleged; not relevant | Denied - not shown relevant or applicable |
| Standard for judicial notice | Plaintiffs invoked federal/state rules (201, Wyoming rules/statutes) | Only federal procedural law applies in federal court | Denied - wrong procedural standards |
| Relevance to fire cause | Statutes/treatises help prove/disprove cigarette cause of fire | No evidence cigarettes in question subject to these standards | Denied - no evidentiary link, speculative |
Key Cases Cited
- York v. American Tel. & Tel. Co., 95 F.3d 948 (10th Cir. 1996) (explains judicial notice as a device to alleviate evidentiary burdens)
- United States v. Gould, 536 F.2d 216 (8th Cir. 1976) (clarifies distinction between legislative and adjudicative facts)
- United States v. Williams, 442 F.3d 1259 (10th Cir. 2006) (legislative facts and proper use in judicial notice)
- United States v. Wolny, 133 F.3d 758 (10th Cir. 1998) (judicial notice does not override evidentiary relevancy requirements)