At the start of any lawsuit, a plaintiff must file an initial complaint, detailing the reasons why he or she is suing. In order to weed out frivolous or unsupported lawsuits that will only bog down the court system, plaintiffs must plead their claims with sufficient specificity and facts so that the claim that they are making is obvious from the face of the complaint. This is known as the Twombly/Iqbal standard. Thus, for instance, a plaintiff cannot simply file a complaint that says that he or she was injured because the defendant hurt him or her. Instead, the complaint must provide some degree of detail on how the injury occurred and why the defendant is at fault in order for a claim against the defendant to survive. However, this does not mean that the plaintiff must know every fact and detail. That is what the discovery phase of litigation is meant to address. A recent case before the Sixth Circuit Court of Appeals considers what to do when a court holds litigants to too high a standard of pleading under Twombly and Iqbal.
In Jackson v. Ford Motor Company, Mr. Jackson was killed, and Ms. Jackson was seriously injured, when they lost control of their 2012 Ford Focus while driving. Ms. Jackson brought this lawsuit, arguing that Ford Motor Company was to blame because a defect in the car caused her husband to lose control. Specifically, she claimed that the Electronic Power Assisted Steering (EPAS) in the car failed, causing the steering wheel to become uncontrollable and leading to the car veering into oncoming traffic. At the trial court level, Ford filed a motion to dismiss, arguing that Ms. Jackson failed to plead proximate cause (that Ford was actually the cause of her accident and injury) and that the complaint should be dismissed. The trial court granted the motion. Ms. Jackson appealed.
Ms. Jackson’s complaint stated that the EPAS was the cause of her injuries and her husband’s death. To support this claim in her complaint, she detailed the defect in the EPAS system that she alleged, including manufacturing defects and a misalignment of cables in the system. According to her complaint, these defects make the EPAS system vulnerable to failure and cause drivers to lose control of their cars. In further support of these claims, Ms. Jackson also detailed three prior incidents of EPAS failure in Ford Focus vehicles, as well as similar failures in other vehicles with EPAS systems. Based on these facts, Ms. Jackson sued Ford for manufacturing and design defects, defective warnings, and negligent manufacture.
Ford argued that although Ms. Jackson went to great lengths to detail the nature of the defects she alleged, she did not show how these defects actually caused her car to veer into oncoming traffic. It noted that she did not specify the exact flaw that caused her accident to occur. Although the trial court agreed with these arguments, the Sixth Circuit reversed. It held that Ms. Jackson had stated a plausible claim for relief and had adequately pleaded causation. It noted that under Tennessee law, there is a three-factor test for proximate cause: (1) the defendant’s conduct was a substantial factor in the harm alleged, (2) there is no rule or policy that prevents the defendant from being liable, and (3) the harm giving rise to the lawsuit could have been foreseen or anticipated by a person of ordinary intelligence.
Here, the Sixth Circuit determined that Ms. Jackson adequately alleged that the defect in the EPAS system was a substantial factor in her accident, and there was no rule or policy that prevented Ford from being held liable for such defects. Finally, it determined that a person of ordinary intelligence could have foreseen that the defects could cause an accident, given their severity. The Sixth Circuit concluded that Ford’s attacks on Ms. Jackson’s complaint were overly technical and attempted to apply a higher standard for pleading than was required under the law. Accordingly, it reversed the trial court’s decision and remanded for further proceedings.
When filing a civil lawsuit, it is extremely important to pay attention to pleading standards to ensure that your complaint can survive a motion to dismiss. Defendants will be quick to jump on allegations that are unsupported by the facts or overly vague. Knowledgeable Tennessee personal injury attorney Eric Beasley can help you prepare a complaint that adequately meets the Iqbal and Twombly standards while allowing flexibility for continued discovery. For more information or to discuss the circumstances of your case, contact the Law Office of Eric Beasley today at 615-859-2223.
Related Blog Posts:
Foreseeability As a Question of Fact in Tennessee Courts, Tennessee Personal Injury Blog, September 14, 2016
The Necessity of Proving Causation in Tennessee Auto Accident Claims -Denton v. Taylor, Tennessee Personal Injury Blog, August 18, 2016
What Constitutes a Known Dangerous Condition in Tennessee, Tennessee Personal Injury Blog, June 7, 2016.