Love v. Weeco™
United States Court of Appeals for the Eleventh Circuit
774 Fed. Appx. 519 (2019)
Irvin Love (plaintiff) bought a Weeco hoverboard through Amazon.com, Inc. (defendant) that came with no fire-risk warnings, and its lithium-ion battery started a fire injuring Love and destroying his home; Love sued, alleging Amazon negligently sold Chinese-manufactured hoverboards known to cause fires, citing multiple reported fires from lithium-ion hoverboard batteries and U.S. Customs' seizure of thousands of such devices, and alleging Amazon had written notice of four prior fires from hoverboards it sold, though without identifying the specific models involved. The trial court dismissed Love's failure-to-warn claims against Amazon for insufficient notice allegations, and Love appealed.
Whether, in negligent failure-to-warn claims, courts infer knowledge that a product is dangerous if it contains a component known to be dangerous in other products.