Country Mutual Insurance Company v. Broan Nutone, LLC
- Katherine Menendez
- 0:20-cv-02251
- U.S. District Court · District of Minnesota
- 8
Country Mutual v. Broan-Nutone: Judge Doty dismissed A.O. Smith with prejudice after finding no personal jurisdiction over it in Minnesota.
A.O. Smith Corporation was dismissed from the action with prejudice, ending the plaintiffs’ claims and the parties’ crossclaims against A.O. Smith in this case. The claims against Broan-Nutone were not resolved by this order.
What happened
Country Mutual Insurance Company and State Farm Fire and Casualty Company sued Broan-Nutone, LLC and A.O. Smith Corporation after a bathroom fan caused a fire in Minnesota. They sought compensation for insured property damage and brought strict-liability, negligence, and warranty claims.
A.O. Smith asked the court to dismiss all claims and crossclaims against it because it lacked sufficient connections with Minnesota. The court found that A.O. Smith did not make, sell, or assemble the motor or fan in Minnesota, and that Broan’s sale of the fan there did not establish the required connection.
Judge David S. Doty granted A.O. Smith’s motion and dismissed A.O. Smith from the case with prejudice. The ruling addressed the court’s authority over A.O. Smith, not whether the underlying fire-related claims were correct.
The detailed version
- Country Mutual Insurance Company v. Broan Nutone, LLC · No. 0:20-cv-02251
- Katherine Menendez
- July 1, 2021
Background
Country Mutual Insurance Company, doing business as Middleoak, and State Farm Fire and Casualty Company sued Broan-Nutone, LLC and A.O. Smith Corporation. The dispute arose from a June 28, 2019, fire in a Minnesota building. A bathroom ceiling fan allegedly started the fire and damaged two residential units. The plaintiffs had provided property insurance to the homeowners’ association and residents and brought the case after paying insurance claims.
The plaintiffs asserted strict-liability, negligence, and breach-of-warranty claims. Broan designed, manufactured, assembled, and distributed the fan, which contained an A.O. Smith motor. Broan and A.O. Smith also brought crossclaims against each other for indemnity and contribution.
A.O. Smith moved to dismiss all claims and crossclaims against it for lack of personal jurisdiction. Personal jurisdiction is a court’s authority to exercise its power over a particular defendant. Broan and the plaintiffs opposed the motion.
Personal Jurisdiction
The court explained that personal jurisdiction requires sufficient contacts between the defendant and Minnesota so that the defendant could reasonably anticipate being sued there. The court considered both general jurisdiction and specific jurisdiction.
The court rejected general jurisdiction because A.O. Smith was incorporated in Delaware and had its principal place of business in Wisconsin, not Minnesota. The court also found no basis to treat Minnesota as an exceptional additional location where A.O. Smith was effectively at home.
The court then considered specific jurisdiction, which requires sufficient contacts with Minnesota connected to the claims in the case. Broan and the plaintiffs relied on A.O. Smith’s website, which directed Minnesota consumers to third-party water-heater retailers and technicians. The court found those contacts unrelated to the claims, which concerned A.O. Smith’s fan motor rather than its water-heater products.
The court also found that A.O. Smith had not designed, manufactured, or sold the motors in or to Minnesota, and had not assembled or distributed Broan’s bathroom fans. A.O. Smith’s motor reached Minnesota because of Broan’s actions in selling the fan, not because A.O. Smith purposefully conducted activities there. The court therefore held that Minnesota could not exercise specific jurisdiction over A.O. Smith.
Disposition
The court granted A.O. Smith’s motion to dismiss. It ordered that A.O. Smith be dismissed from the action with prejudice, meaning the dismissal barred the claims against A.O. Smith from being brought again in this action. The opinion resolved the jurisdictional issue and did not decide the merits of the plaintiffs’ underlying claims concerning the fire, the fan, or the motor.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.