Products Liability Law Reporter

A federal district court held that a consumer who was allegedly injured when an 18650 lithium-ion battery exploded in his pants pocket could not hold LG Chem, Ltd., responsible in a products liability suit.

Jeffrey Huntington was carrying a 18650 lithium-ion battery in his front pocket when the battery exploded and his pants caught fire. Huntington was injured and brought a products liability suit against LG Chem, Ltd., and Smoke City for Less LLC. LG Chem moved to dismiss, arguing that the court did not have general or specific jurisdiction.

Granting the motion, the district court noted it was undisputed that LG Chem had shipped 18650 lithium-ion batteries into Washington and entered into transactions with companies involving the battery cells. Thus, the court said, LG Chem’s contacts with Washington show that it purposefully availed itself of the privilege of doing business there by shipping batteries to Washington ports.

Nevertheless, the court found that the plaintiff did not show that his injuries were related to LG Chem’s shipments of lithium-ion batteries into Washington. Citing case law, the court said that LG Chem’s shipment of lithium-ion cells encased in battery packs with protective circuitry for use in industrial components did not cause injuries similar to those the plaintiff alleged here. Moreover, LG Chem could not have foreseen the risk that its batteries might cause the plaintiff’s injuries because the company did not intend for consumers to handle its battery packs.

Finding that the plaintiff did not submit evidence demonstrating LG Chem served the consumer market for standalone, replaceable lithium-ion batteries, the court held that the plaintiff did not establish personal jurisdiction.

Citation: Huntington v. Smoke City for Less LLC, 2023 WL 2996729 (E.D. Wash. Apr. 18, 2023).