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Payne v. Benchmaster Furniture, LLC

United States District Court, E.D. Louisiana

January 10, 2017

JAMIE & LEE PAYNE
v.
BENCHMASTER FURNITURE, LLC

         SECTION “L” (3)

          ORDER & REASONS

         Currently pending before this Court in this case is Plaintiffs' Motion to Certify Class (R. Doc. 7). After considering the parties' briefs and applicable law, the Court now issues this order and reasons.

         I. BACKGROUND

         Plaintiffs Jamie Payne (“Mrs. Payne”) and Lee Payne (“Mr. Payne”), who are Louisiana Residents, brought suit against BenchMaster for an alleged defect in a “Nicholas” leather recliner manufactured by the Defendant BenchMaster Furniture. (R. Doc. 1). Plaintiffs allege that when the recliner is engaged, the backrest and the seat create a “pinch point hazard.” Plaintiffs allege that on February 8, 2014, Mrs. Payne attempted to place the chair in the reclined position, at which point her right hand became entrapped in the “pinch point.” This allegedly caused an amputation of a segment of her right middle finger.

         Plaintiffs set forth several theories of liability against BenchMaster including negligence, products liability, and redhibition. Plaintiffs bring class allegations on behalf of all purchasers of the BenchMaster Nicholas chair throughout the United States.

         On August 18, 2015, Plaintiffs amended their complaint to add Golden Eagle Insurance Company, BenchMaster's insurer, as well as several other theories of liability, including breach of warranty. (R. Doc. 15). Additionally, Plaintiffs - despite the fact they are Louisiana residents and have no named California residents as class members-added a claim under California's product defect law.

         On November 17, 2015, this Court granted in part and denied in part Defendant BenchMaster's motion to dismiss Plaintiffs' amended complaint. (R. Doc. 39). BenchMaster's motion was granted as unopposed as to Plaintiffs' claims arising under California law and those claims were dismissed without prejudice. BenchMaster's motion was denied as to the dismissal of Plaintiffs' class allegations.

         II. LAW & ANALYSIS

         A. Standard of Review

         The proponents of the class bear the burden of demonstrating that the case is appropriate for class treatment. Berger v. Compaq Computer Corp., 257 F.3d 475, 479 n.4 (5th Cir. 2001). Class certification is soundly within the district court's discretion, and this decision is essentially a factual inquiry. Vizena v. Union Pac. R.R. Co., 360 F.3d 496, 502-03 (5th Cir. 2004). The class certification decision generally should not reach the merits of the plaintiffs' claims. Castano v. Am. Tobacco Co., 84 F.3d 734, 744 (5th Cir. 1996). However, in some cases it is necessary for a district court to go beyond the pleadings to understand the claims, defenses, substantive law, and relevant facts in order to make a meaningful certification decision. Id. The district court must make specific findings regarding how the case satisfies or fails to satisfy the requirements of Rule 23 of the Federal Rules of Civil Procedure. Vizena, 360 F.3d at 503. Using these standards as a guide, the Court will now analyze the requirements for class certification.

         B. Class Certification

         Plaintiffs seek certification of their claims as a class action under Rule 23(b)(1) and/or 23(b)(3) of the Federal Rules of Civil Procedure. Rule 23 provides in relevant part:

         (a) Prerequisites. One or more members of a class may sue or be sued as representative parties on behalf of all members only if: (1) the class is so numerous that joinder of all members is impracticable; (2) there are questions of law or fact common to the class; (3) the claims or defenses of the representative parties are typical of the claims or defenses of the class; and (4) the representative parties will fairly and adequately protect the interests of the class.

         (b) Types of Class Actions. A class action may be maintained if ...


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