Justia Maryland Supreme Court Opinion Summaries

A woman developed mesothelioma and lung cancer, allegedly caused by exposure to asbestos dust brought home on her husband’s work clothing. Her husband had applied asbestos-containing insulation to power generation turbines manufactured by a company at a Maryland power plant in the 1960s. The plaintiff did not work at the plant or use the product herself but routinely shook out and laundered her husband’s dusty clothes. After her death, her estate continued the lawsuit, asserting a strict liability design defect claim against the turbine manufacturer and others.The Superior Court of the District of Columbia initially granted summary judgment for the manufacturer on all claims. On appeal, the District of Columbia Court of Appeals vacated the grant of summary judgment as to the strict liability design defect claim and remanded the case. Following remand, the Superior Court again granted summary judgment for the manufacturer, concluding that, under Maryland law, the plaintiff could not recover as a bystander. The plaintiff appealed, and the District of Columbia Court of Appeals certified a question of law to the Supreme Court of Maryland, asking whether a household member claiming injury from asbestos dust must prove an additional element of “duty” beyond the four elements of strict liability under Maryland law.The Supreme Court of Maryland held that a household member in the plaintiff’s position need not prove the additional element of duty to recover on a strict liability design defect claim in an asbestos case. The court emphasized that, unlike negligence or failure to warn claims, strict liability design defect actions require only the four elements identified in Phipps v. General Motors Corp. The court clarified that “duty” is not an additional element for such claims, regardless of whether the plaintiff is a “user,” “consumer,” or a household member exposed through no fault of their own. View "Quinn v. General Electric Co." on Justia Law