Western Federal District Court Holds That E-Commerce Platform (Such as Amazon.com or Wal-Mart.com) Cannot Be Held Liable for Defective Products

In the case of Rimel v. Alabama Janitorial & Paper Supply, LLC, No. 23-CV-2020 (W.D. Pa. Sept. 2, 2026 Stickman, J.), the Federal Western District Court of Pennsylvania addressed the novel issue of whether an e-commerce platform like Amazon or Wal-Mart may be held liable for injuries resulting to a plaintiff from the use of products manufactured and sold by third party vendors that use the platforms to sell their products.

In its Opinion the Rimel Court noted that neither the Third Circuit nor the Pennsylvania Supreme Court had previously ever decided the extent of liability, if any, that an e-commerce platform might have in a products liability action. See Op. at p. 7-8.

In this case, the Court addressed motions for summary judgment filed by various defendants in the matter.

The Plaintiff was a United Postal Service distribution center worker who suffered severe chemical burns when she picked up a bottle of Liquid Fire, which was a drain cleaner, and which was stuck on a conveyor belt.

The bottle of drain cleaner was purchased by a customer in Virigina on Walmart.com from a third-party seller and shipped from a third-party warehouse located in Illinois.

Plaintiff filed suit in product liability and negligence. The Plaintiff's product liability claims were dismissed earlier in the case.

Discovery on the remaining negligence claims confirmed that Walmart, as the e-commerce platform, never had possession of the bottle of Liquid Fire, that it was not the seller, and that Walmart played no role in the shipment of the bottle.

The Western Federal District Court granted summary judgment to various defendants, including Wal-mart.com as the e-commerce platform defendant.

In so ruling the Rimel Court stated that “the Supreme Court of Pennsylvania has never directly addressed whether e-commerce platforms, such as Walmart or Amazon, may be liable for a plaintiff's injuries where, as here, a third-party vendor sells the goods on the website, but stores, packages and ships the products itself.” See Op. at p. 6.

After looking to other federal district courts decisions from around the country on this issue, the Court in Rimel held that Walmart had no duty to the plaintiff.

The Court more specifically stated that “[a]s a general matter, the Court holds that e-commerce platforms, like Walmart here (and Amazon [ ]), do not owe any duty of care relating to products sold by third-party vendors on their websites. See Op. at p. 11.

Rather, in this scenario, e-commerce platforms are viewed by the courts as not being a manufacturer, seller, or shipper of the product. Rather, the e-commerce platform is viewed as only being an online marketplace for third parties to conduct their business. See Op. at p. 11.

The Rimel Court otherwise also noted that "[u]nder Pennsylvania law ‘there is no duty to control the conduct of a third party to protect another from harm.’” See Op. at p. 12.

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

I send thanks to Attorneys Kenneth T. Newman and Richard T. Murphy of the Pittsburgh office of Thomas, Thomas & Hafer for bringing this case to my attention.


Source of image: Photo by Karola G on www.pexels.com.