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Keywords

lawsuitdefendantliabilityappealtrialsummary judgmentstrict liability
lawsuitdefendantliabilityappealtrialsummary judgmentstrict liability

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Bolger v. Amazon.com, LLC, 53 Cal.App.5th 431, 267 Cal.Rptr.3d 601, Prod.Liab.Rep. (CCH) P 20,955, 20 Cal. Daily Op. Serv. 8180, 2020 Daily Journal D.A.R. 8836

Facts

Angela Bolger purchased a replacement laptop battery from Amazon, which was sold by a third-party seller, Lenoge Technology (HK) Ltd., under the name 'E-Life.' Amazon charged Bolger for the battery, stored it in its warehouse, and shipped it in Amazon-branded packaging. After several months, the battery exploded, causing Bolger severe burns, leading her to file a lawsuit against Amazon and other defendants for various claims including strict products liability.

Angela Bolger purchased a replacement laptop battery from Amazon, which was sold by a third-party seller, Lenoge Technology (HK) Ltd., under the name 'E-Life.' Amazon charged Bolger for the battery, stored it in its warehouse, and shipped it in Amazon-branded packaging. After several months, the battery exploded, causing Bolger severe burns, leading her to file a lawsuit against Amazon and other defendants for various claims including strict products liability.

Issue

Whether Amazon.com, LLC can be held strictly liable for a defective product sold by a third-party seller on its platform.

Whether Amazon.com, LLC can be held strictly liable for a defective product sold by a third-party seller on its platform.

Rule

The doctrine of strict products liability applies to entities involved in the distribution of consumer goods, holding them liable for defects regardless of their role in manufacturing or direct selling.

The doctrine of strict products liability applies to entities involved in the distribution of consumer goods, holding them liable for defects regardless of their role in manufacturing or direct selling.

Analysis

The court determined that Amazon acted as a pivotal intermediary in the distribution chain between Lenoge and Bolger. By accepting possession of the product, storing it, processing the payment, and shipping it in Amazon-branded packaging, Amazon placed itself in the chain of distribution, thus making it subject to strict liability for any defects in the product.

The court determined that Amazon acted as a pivotal intermediary in the distribution chain between Lenoge and Bolger. By accepting possession of the product, storing it, processing the payment, and shipping it in Amazon-branded packaging, Amazon placed itself in the chain of distribution, thus making it subject to strict liability for any defects in the product.

Conclusion

The Court of Appeal reversed the trial court's summary judgment in favor of Amazon, concluding that Amazon could be held strictly liable for the defective battery sold by Lenoge.

The Court of Appeal reversed the trial court's summary judgment in favor of Amazon, concluding that Amazon could be held strictly liable for the defective battery sold by Lenoge.

Who won?

Angela Bolger prevailed in the appeal because the court found that Amazon's role in the transaction made it liable under the doctrine of strict products liability.

Angela Bolger prevailed in the appeal because the court found that Amazon's role in the transaction made it liable under the doctrine of strict products liability.

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