McNeilus Truck and Manufacturing, Inc. v. Swagelok Company

Background

McNeilus Truck and Manufacturing, Inc. manufactures commercial trucks. The case concerns an explosion on January 11, 2017, at McNeilus’s manufacturing facility. McNeilus alleged that the explosion resulted from the failure of a hose assembly designed and manufactured by Swagelok Company and distributed by San Diego Valve & Fitting Co., Inc. McNeilus had installed the hose assembly on a truck, and it allegedly came apart during manufacturing, releasing compressed natural gas.

McNeilus asserted claims for negligence, strict liability, and breach of express and implied warranties.

Defendants’ Summary-Judgment Motion

The defendants moved for summary judgment on all of McNeilus’s claims. They argued that McNeilus’s own negligence was, as a matter of law, a superseding cause and the sole proximate cause of the explosion. Summary judgment is a decision entered without a trial when the governing legal standard is met and no genuine dispute of material fact requires a trial.

The court denied the defendants’ motion. It found genuine issues of material fact concerning whether McNeilus was negligent and whether any negligence by McNeilus was a superseding cause of the explosion.

McNeilus’s Joint-Venture and Joint-Enterprise Motion

McNeilus moved for a declaration that Swagelok and San Diego Valve were joint venturers. It argued that their fault therefore had to be aggregated when applying Minnesota’s comparative-fault statute, Minnesota Statutes § 604.01.

The court found a genuine factual dispute about whether the defendants shared profits, which the court identified as a necessary element of a joint venture. The court also declined to grant judgment on McNeilus’s alternative joint-enterprise argument because McNeilus raised that argument for the first time in its reply brief, leaving the defendants without an opportunity to respond. The court further stated that it would be preferable to develop a full trial record before deciding whether the defendants were involved in a joint venture, a joint enterprise, or both. The court denied McNeilus’s motion on this issue.

Spoliation Motion

McNeilus separately moved for summary judgment on the defendants’ affirmative defense of spoliation. Spoliation concerns the destruction of evidence. McNeilus sought a ruling, before trial, that the court would not give the jury an adverse-inference instruction—an instruction that could allow jurors to draw a negative conclusion from the destruction of evidence.

The defendants had not sought dismissal of McNeilus’s claims or defenses as a spoliation sanction. Instead, they appeared to be considering requesting an adverse-inference instruction at the end of trial. Based on the limited record then available, the court stated that it would not give such an instruction. But the court also said it could not make a final ruling because it had not determined that McNeilus destroyed evidence in order to suppress the truth. The court deferred a final decision on jury instructions and other spoliation remedies until after hearing the evidence at trial. McNeilus’s motion concerning the spoliation defense was denied without prejudice.

Order

The court ordered that the defendants’ motion for summary judgment was denied and that McNeilus’s motion for partial summary judgment was denied. The order did not resolve the disputed factual questions about negligence, causation, the relationship between the defendants, or possible spoliation remedies. Patrick J. Schiltz signed the order as the United States District Judge.