Judge Mannion of Federal Middle District Court Addresses Punitive Damages Claims in Products Liability Context

In the case of Dyvex Industries, Inc. v. Agilex Flavors & Fragrances, Inc., No. 12 - CV - 0979 (M.D. Pa. Feb. 12, 2018 Mannion, J.), Judge Malachy E. Mannion of the Federal Middle District Court of Pennsylvania addressed the current status of punitive damages law in the context of a products liability case. Ultimately, the court found that the Plaintiff failed to plead facts sufficient to support a claim for punitive damages under the case presented.  

Generally speaking, the court noted that Plaintiff law requires conduct on the part of a Defendant that is so outrageous as to demonstrate willful, wanton, or reckless conduct.   The law also requires that a subjective appreciation of the risk of danger is also necessary to support such a claim.  

In this case, the court found that, since the moving Defendant did not retain any control over any aspect of the manufacturing of the subject product, that Defendant could not be found to have had the requisite culpable mental state to support a claim of punitive damages against the Defendant.  The court also noted that the record revealed that this Defendant was in compliance with all applicable regulations.  

Judge Malachy E. Mannion
M.D. Pa.

Judge Mannion otherwise noted that entering the law does not allow for punitive damages under a claim of a breach of contract.  

Ultimately, the court found that the evidence revealed that, at most, the moving Defendant’s conduct amounted to negligence, which is insufficient to support a claim for punitive damages as a matter of law.  

Anyone wishing to review a copy of this decision may click this LINK.  

I send thanks to Attorney James M. Beck of the Philadelphia office of the law firm of Reed Smith for bringing this case to my attention.