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Keywords

lawsuitliability
jurisdiction

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Rennert v. Great Dane Ltd. Partnership, 543 F.3d 914, RICO Bus.Disp.Guide 18,090

Facts

On July 1, 2005, Rabbi Shmuel Rennert and his wife Devorah were driving behind a large truck towing a trailer designed by Great Dane. Their minivan collided with the trailer, and the underride guard failed, causing the minivan to slip underneath the trailer. Shmuel was injured, while Devorah was killed. Rennert subsequently filed a lawsuit against Great Dane, claiming strict products liability due to the allegedly defective underride guard.

On July 1, 2005, Rabbi Shmuel Rennert and his wife Devorah were driving on Skokie Valley Road behind a large truck towing a trailer designed by Great Dane. Unfortunately, the Rennerts' minivan collided with the trailer; the underride guard on the back of the trailer failed; and the minivan slipped under the trailer.

Issue

Whether the allegations regarding the trailer's badly designed underride guard assert a recognizable cause of action under Illinois law.

Whether the allegations regarding the trailer's badly designed underride guard assert a recognizable cause of action under Illinois law.

Rule

Under Illinois law, a manufacturer has a duty to design a vehicle that is reasonably safe for its occupants, but it does not owe a duty to protect those who collide with its vehicle.

A manufacturer has a duty to design a vehicle that is reasonably safe for the occupants, but it owes no duty to those who collide with that vehicle.

Analysis

The court analyzed the allegations made by Rennert and determined that they did not meet the legal standards set by Illinois courts. The court referenced previous rulings, particularly Mieher and Beattie, which established that claims similar to Rennert's had been dismissed in the past. The court concluded that the Illinois Supreme Court would likely not recognize a cause of action based on the allegations presented.

Given the consistent position Illinois has taken, we would need strong evidence that the Supreme Court of Illinois is on the brink of changing its position before we could do likewise.

Conclusion

The court affirmed the district court's dismissal of Rennert's claim, concluding that the allegations did not constitute a valid cause of action under Illinois law.

The judgment of the district court is Affirmed.

Who won?

Great Dane Trailers prevailed in the case because the court found that the allegations did not assert a recognizable cause of action under Illinois law, consistent with previous rulings.

Great Dane removed to federal court under diversity jurisdiction. Once in federal court, Great Dane moved to dismiss under Fed.R.Civ.P. 12(b)(6) for failure to state a claim. The district court dismissed the claim with prejudice; we generally agree with its analysis and affirm.

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