Thompson v. Brasscraft Manufacturing Company

Background

Brasscraft manufactured water supply lines that connect household toilets to a water source. During construction of the Thompsons’ house, Walt Thompson, a licensed plumber, installed a Brasscraft water supply line in one of the house’s three bathrooms. The installation took no more than five minutes and required only a wrench and Thompson’s hands. The house was completed in 2003. Fifteen years later, a plastic coupling nut on the supply line failed, causing significant water damage.

Walt and Kristine Thompson sued Brasscraft for negligence, products liability, and breach of warranty. Brasscraft moved for summary judgment, arguing that Minnesota Statutes § 541.051 barred the claims under its statute of repose.

Summary-judgment standard

The court explained that summary judgment is appropriate when the evidence shows no genuine dispute about a material fact and the moving party is entitled to judgment as a matter of law. Because the case was in federal court based on diversity jurisdiction, the court applied Minnesota law.

Statute of repose

Section 541.051 generally bars actions seeking damages for injury to property caused by a defective improvement to real property when the action is brought more than ten years after substantial completion of construction. The statute contains an exception for the manufacturer of equipment or machinery installed on real property.

The court stated that the Thompsons’ claims accrued more than ten years after substantial completion of the house. Thus, the claims were barred if the water supply line was an improvement to real property and did not qualify as equipment under the statutory exception.

Improvement to real property

The court held that the water supply line was an improvement to real property. Under Minnesota law, an improvement is a permanent addition or betterment that enhances the property’s value, involves labor or money, and is designed to make the property more useful or valuable rather than merely to perform an ordinary repair.

The court found that the supply line met those considerations. It was an integral part of the bathroom’s plumbing system, connected the toilet to the building’s water supply, was required by Minnesota building codes, and was not designed for regular replacement. Although it was inexpensive, easy to remove, and quick to install, the court concluded that those facts did not prevent it from being a permanent improvement. The court also found that a house with a functioning toilet is more useful and valuable than one without one.

Equipment exception

The court separately held that the supply line was not “equipment” under § 541.051, subdivision 1(e). It predicted that Minnesota would interpret equipment narrowly, as machinery, tools used in an operation or activity, or certain fixed assets. The supply line was merely a pipe connecting the toilet to the water supply. It was neither a machine nor a tool and had no independent operation or use apart from its role in the plumbing system.

The court rejected the Thompsons’ comparison to sprinkler heads and relied on the distinction between the supply line and equipment that has a separate function. Because the supply line was not equipment, the statutory exception did not apply.

Disposition

The court concluded that the supply line was an improvement to real property and was not equipment under the statutory exception. It therefore ruled that Minnesota’s statute of repose barred the Thompsons’ claims. The court granted Brasscraft Manufacturing Company’s Motion for Summary Judgment and ordered that judgment be entered. Susan Richard Nelson signed the order as the United States District Judge.