Knautz v. 3M Company
- John Tunheim
- 0:21-cv-01765
- U.S. District Court · District of Minnesota
- 6
In Knautz v. 3M Company, Judge Tunheim granted remand motions and returned six earplug cases to Minnesota state court.
The six plaintiffs’ cases against 3M Company and Aearo Technologies LLC were returned from federal court to Minnesota state court; the underlying product-liability claims were not decided.
What happened
Knautz v. 3M Company involved six lawsuits by people who used 3M and Aearo Technologies’ combat earplugs and alleged inadequate warnings caused hearing loss or tinnitus.
3M moved the cases from Minnesota state court to federal court, arguing that a government-contractor defense created federal jurisdiction. After an earlier similar ruling was upheld on appeal, 3M agreed that the cases should return to state court.
Judge Tunheim granted five plaintiffs’ motions to remand and ordered the sixth case, Adams v. 3M Company, remanded even though its plaintiff had not formally filed a motion.
The detailed version
- Knautz v. 3M Company · No. 0:21-cv-01765
- John Tunheim
- Nov. 26, 2021
Background
This opinion addresses six related cases captioned Knautz, Campbell, Brown, Hatfield, Moore, and Adams against 3M Company and Aearo Technologies LLC. The plaintiffs alleged that they used Combat Arms Earplugs, Version 2, while performing civilian work involving loud noises. They claimed that 3M failed to provide adequate instructions and warnings about properly fitting and wearing the earplugs, including the need to fold back the third flange. They alleged that they suffered hearing loss and/or tinnitus as a result.
Removal to Federal Court
The plaintiffs originally filed product-liability lawsuits in Minnesota state court. 3M removed the cases to federal court, arguing that the federal court had subject-matter jurisdiction based on the government-contractor defense. That defense was the basis 3M offered for federal jurisdiction in these cases.
In an earlier factually similar case, the court concluded that 3M had not properly raised a colorable government-contractor defense concerning the alleged warning-related conduct. The Eighth Circuit later affirmed, stating that 3M had not shown that the government dictated or controlled the nature and content of its product warnings. After that decision, 3M abandoned its opposition to remand, and the parties agreed that remand was proper.
Court’s Analysis
A defendant may remove a civil case to federal court only when the case could originally have been filed there. The defendant seeking removal has the burden of establishing federal subject-matter jurisdiction. The court explained that an uncontested motion to remand must be granted.
3M presented no argument against remand, and the parties agreed that remand was proper in all six cases. Although the plaintiff in Adams did not formally move for remand, the parties and the court agreed that the basis for federal jurisdiction in Adams was identical to the basis in the other cases and was lacking.
Ruling
Judge John R. Tunheim ordered that the remand motions in Knautz, Campbell, Brown, Hatfield, and Moore were granted. The court also ordered that Adams be remanded to the State of Minnesota District Court, Fourth Judicial District, Hennepin County. The opinion did not decide the plaintiffs’ underlying product-liability claims.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.