Products Liability Law Reporter

A Florida appellate court held that Samsung SDI Co. was not liable to a consumer who was severely burned when his vaping device exploded because the plaintiff failed to establish personal jurisdiction over the company.

Bennett Fields carried a vaping device containing cylindrical Samsung 18650 lithium ion batteries in his front pants pocket. The device exploded, causing him to suffer serious burn injuries. Fields filed suit against Samsung SDI Co., which manufactured the batteries, in Florida state court. The defendant moved to dismiss the case for lack of personal jurisdiction, and the trial court denied the motion.

Reversing, the appellate court noted that Florida courts apply a two-step analysis when determining whether the state may exercise personal jurisdiction over a foreign corporation. Citing case law, the court found that personal jurisdiction exists where an action falls within the state’s long-arm statute and the defendant has sufficient minimum contacts to satisfy federal due process requirements.

The plaintiff failed to connect his injury to Samsung’s business activities in Florida, the court said, adding that the most substantial part of Samsung’s Florida business is its sale of large batteries to utility companies. Moreover, the court found that the complaint did not allege Samsung committed a tortious act within the state. The fact that the plaintiff was injured in Florida does not, by itself, lead to a conclusion that Samsung committed a tort in the state, the court said.

Finally, the court found that the plaintiff had failed to establish that Samsung had manufactured or serviced a product used in Florida during the ordinary course of commerce and trade. The company specifically prohibits its 18650 batteries from being used in vaping devices, the court said, and does not sell them for that purpose.

Consequently, the court remanded, directing the trial court to dismiss the plaintiff’s action against Samsung.

Citation: Samsung SDI Co. v. Fields, 2022 WL 1562290 (Fla. Dist. Ct. App. May 18, 2022).