In Teague v. Norcold, Inc., the plaintiff alleged that a defective refrigerator manufactured by Norcold caused a fire that destroyed his RV and personal property while he was using the vehicle as temporary housing, leading to claims for products liability, negligence, breach of warranty, and violations of the Texas DTPA. The court ruled on the defendant's motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), granting it in part and denying it in part based on Texas's economic-loss rule. The court held that tort claims seeking recovery for the value of the refrigerator itself were barred by the rule, as it treats the unit as a component part of the RV and limits plaintiffs to contract remedies for such losses, but denied dismissal of tort claims for damage to other property. The court also denied dismissal of the breach-of-warranty and DTPA claims, determining that additional facts were needed to resolve whether the unit was a discrete product or component and to evaluate the warranty issues.
The case involves Panorama Construction suing Farm Credit Services and Heartland Recovery in Texas state court over state-law claims including fraud and tortious interference with contract against Farm Credit, plus a foreclosure action on mechanic's liens against Heartland, after Farm Credit foreclosed on property improved by Panorama and Heartland acquired it. Farm Credit removed the action to federal court on diversity grounds, asserting that in-state defendant Heartland had been improperly joined. The court denied Panorama's motion to remand, concluding that Heartland was improperly joined because Panorama could not establish a valid lien claim against it, as Farm Credit's earlier-recorded deeds of trust had priority under Texas rules on mechanic's liens and property conveyances.
This case involved a dispute over long-term disability benefits under an ERISA-governed insurance plan. Dr. Bruce Leipzig, an otolaryngologist, sought continued benefits after Principal Life Insurance Company stopped payments following the initial own-occupation period, arguing his eye disorder prevented him from performing surgeries and earning sufficient income in his limited market. Principal determined that Leipzig could perform patient consultations full-time and earn at least two-thirds of his prior earnings, thus not meeting the plan's definition of disability for any gainful occupation or modified duties. The court granted summary judgment to Principal, finding its interpretation of the plan reasonable and not an abuse of discretion, while denying Leipzig's motion and dismissing his breach of fiduciary duty claim. The decision emphasized that local market conditions did not qualify as a disability under the policy terms.
This case involved a dispute between motor carriers Landair and Schneider over liability for a stolen shipment of goods that Wal-Mart had contracted Landair to transport from Mississippi to Texas. Landair subcontracted the job to Schneider, a Wal-Mart-approved carrier, but the shipment was lost en route, causing Wal-Mart to deduct $91,387.70 from Landair's account; Landair then sued Schneider for reimbursement under federal law. The court denied Schneider's motion for summary judgment, which claimed the suit was time-barred by a 9-month deadline in its tariff, and granted Landair's motion, awarding the full amount sought. The ruling rested on the Carmack Amendment's framework imposing near-strict liability on carriers for loss of interstate shipments, the undisputed facts showing Schneider received and lost the goods, and rejection of the timeliness defense.