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State Farm Fire & Casualty Co. v. Amazon.com, Inc.

United States Court of Appeals for the Ninth Circuit
835 F. App’x 213 (2020)

Written by Jamie Milne, JD

Facts

A third-party manufacturer sold its hoverboards on the website operated by Amazon.com, Inc. (Amazon) (defendant). Amazon’s website expressly identified the third party as the hoverboards’ seller. Additionally, Amazon’s Business Services Agreement expressly disclaimed any warranties regarding third-party products. Amazon merely shipped third-party products from warehouses to consumers in exchange for small compensation from the third parties. Amazon did not inspect or take title to third-party products at any point in the process. After some purchased hoverboards caught fire in a consumer’s home, the consumer’s insurance provider, State Farm Fire & Casualty Co. (State Farm) (plaintiff), sued Amazon. State Farm asserted a strict-liability claim, arguing that Amazon was liable because of its role in distributing the defective hoverboards. The district court granted summary judgment in Amazon’s favor, holding that Amazon was not strictly liable because it was not a manufacturer or seller of the hoverboards. State Farm appealed.

Rule of Law

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Issue

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Holding and Reasoning (Smith, J.)

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Dissent (Clifton, J.)

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