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McDaniel v. Kidde Residential and Fire Co.

2015 WL 1326332 (2015)

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McDaniel v. Kidde Residential and Fire Co.

United States District Court for the Western District of Pennsylvania
2015 WL 1326332 (2015)

Facts

Gretchen McDaniel (plaintiff) was making donuts with her daughter, Alaina (plaintiff) when a pot of cooking oil caught fire. Gretchen attempted to put the fire out using a fire extinguisher manufactured by Kidde Residential & Commercial (Kidde) (defendant), but the fire extinguisher failed. Gretchen handed the fire extinguisher to Alaina and sent her to the front of their home. Gretchen then attempted to carry the pot of burning oil through the laundry room toward an exterior door but dropped the pot and suffered severe burns to her face. Alaina did not see her mother being burned, but there was conflicting evidence as to whether she was near enough to the laundry room to hear or smell the injury as it happened. After her mother was burned, Alaina suffered from ongoing nightmares, was fearful of flames, and was anxious and tense. Alaina did not receive medical treatment for her symptoms. Gretchen sued Kidde for negligence, and Alaina brought a separate claim for emotional distress. Kidde moved for summary judgment as to Alaina’s claim.

Rule of Law

Issue

Holding and Reasoning (Fischer, J.)

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