Charles and April Land v. Yamaha Motor Corporation

Notable Items:

Issue(s) Before the Court:

Plaintiff's Claim(s):

Defendant's Claim(s):

Holding(s) and Disposition:

Material Facts:

• June 25, 1998, plaintiff attempted to start a Yamaha WaveRunner on Heritage Lake in Indiana.
• The WaveRunner exploded and caused Land permanent back injury.
• December 23, 1998, plaintiffs filed suit.
• More than 10 years after the WaveRunner was delivered to its first owner.
• Indiana Statute of Repose stipulates that product liability actions must be commenced within 10 years after delivery of the product to the first user or consumer.
• A full recounting of the facts is available below

Procedural History:

• District Court granted summary judgement in favor of the defendants holding that the suit was barred by Indiana Statute of Repose [Limitations].
• Appeal filed and considered by this court.

Rationale

Majority Opinion

• Indiana Statute of Repose stipulates that product liability actions must be commenced within 10 years after delivery of the product to the first user or consumer.
• Indiana applies a two-step conflicts anaylsis to choice-of-law rule.
• First: if the palce where the last event necessary to make the defendant liable (place of injury) is insignificant.
• If significant, the law of the state in which the triggering event occurred applies.
• Place of injury in the instant case is not insignficant...therefore we apply Indiana law.
• Therefore the Indiana Statute of Repose applies.
• A list of the material facts is available above
• A full description of the rationale is available below

Full Recounting of Facts

• June 25, 1998, plaintiff attempted to start a Yamaha WaveRunner on Heritage Lake in Indiana.
• The WaveRunner exploded and caused Land permanent back injury.
• Plaintiff's contend that the WaveRunner was defective in design, allowing gasoline fumes to accumulate inside the hull thereby creating the threat of explosion.
• December 23, 1998, plaintiffs filed suit.
• More than 10 years after the WaveRunner was delivered to its first owner.
• Indiana Statute of Repose stipulates that product liability actions must be commenced within 10 years after delivery of the product to the first user or consumer.
• A list of the material facts is available above

Majority Full Argument

• Indiana Statute of Repose stipulates that product liability actions must be commenced within 10 years after delivery of the product to the first user or consumer.
• Indiana applies a two-step conflicts anaylsis to choice-of-law rule.
• First: if the palce where the last event necessary to make the defendant liable (place of injury) is insignificant.
• If significant, the law of the state in which the triggering event occurred applies.
• If insignificant, court considers: 1) place where conduct causing the injury occurred; 2) residence or place of business of the parties; 3) place where the relationship is centered.
• Place of injury in the instant case is not insignficant...therefore we apply Indiana law.
• Occurrance in Indiana is not mere fortuity...resident of Indiana, owner resides in Indiana, stored in Indiana, choice-of-law analysis ends with step one.
• Therefore the Indiana Statute of Repose applies.
• A list of the material facts is available above
• The core of the rationale is available above