Products Liability Law Daily Wrap Up, DESIGN AND MANUFACTURING DEFECTS—HOUSEHOLD PRODUCTS—E.D. Va.: Defective knobs suit over electric range fire trimmed, claims against Samsung remain, but retailer dismissed, (Oct 29, 2026)

By Wendy Biddle, J.D.

The plaintiffs' allegations fall short of showing that Best Buy knew of the hazard before the recall.

A federal court in Norfolk, Virginia allowed negligence and implied warranty claims to proceed against Samsung Electronics America, Inc. over an alleged range design defect that caused a fire, while dismissing the claims against Best Buy and its related entities. The court held that the complaint plausibly alleged a design defect and causation as to the manufacturer, but did not allege facts showing that the retailer owed or breached a duty under Virginia law (Spinnaker Insurance Co. v. Samsung Electronics America, Inc., No. 2:26-cv-00279-JKW-RJK (E.D. Va. Oct. 27, 2026)).

Background. Cynthia Stokes bought an electric range from BestBuy.com in July 2022, and it was delivered to her home that September. According to the complaint, the range was never turned on, tested, or used before a fire broke out on Nov. 10, 2022. On the morning of the fire, Stokes's son, niece, and mother left the house around 11:00 a.m., each walking through the kitchen and past the range. Combustible materials were on or near the range, and the family members did not intentionally turn any knob to the "on" position. No pets were in the home.

About 90 minutes later, the three returned, noticed the fire, and called 911. The Virginia Beach Fire Department extinguished the blaze. Firefighters concluded that a knob on the right side of the range was in the "on" position and that the combustible material on the stove had ignited. Fire patterns showed damage and discoloration at the right rear surface burner.

In August 2024, Samsung recalled the model. The recall followed more than 300 reports of accidental activation by humans or pets, which resulted in roughly 250 fires. The complaint also alleges that when the patent was first filed in 2019, Samsung acknowledged the range needed a knob stopper or knob cap to prevent unintended operation, and that a 2020 Samsung notice indicated brushing against the front-mounted knobs could activate the appliance absent knob covers or locks.

Spinnaker Insurance Company, as subrogee, and Stokes sued Samsung and Best Buy. The defendants moved to dismiss.

Manufacturing defect claim. The court first addressed the type of defect alleged. Under Virginia law, a manufacturing defect exists where a product fails to conform to its intended design. The court found no allegation that the consumer's unit departed from Samsung's intended design. Instead, the central allegation was that the front-mounted knobs were designed in a way that carried a high risk of accidental activation. The court therefore analyzed the defect claims only under a design defect theory.

The court also rejected the plaintiffs' allegations that Samsung failed to perform adequate quality control inspection and testing. It explained that failure to test or inspect is not an independent theory of products liability in Virginia, because the duty to test is subsumed within the manufacturer's general duty to avoid negligent conduct. Such failures instead bear on whether a manufacturer breached its duty of ordinary care.

Claims against Samsung. Samsung argued that the plaintiffs did not plausibly allege that, but for the claimed defect, the fire would not have occurred. The court first considered whether the complaint alleged a defect rendering the range unreasonably dangerous for ordinary or foreseeable use that existed when the product left Samsung's hands.

The court concluded that it did. The knobs could be moved to the "on" position with a single motion, and their size, shape, and placement exposed them to accidental contact. Samsung's own recall stated that the front-mounted knobs could be activated by accidental contact by humans or pets, posing a fire hazard, and the Consumer Product Safety Commission publicized the recall and reaffirmed that hazard. The court reasoned that people could foreseeably walk past the range and bump knobs positioned at roughly waist level, and that consumers would not expect such a risk. Because foreseeable use sufficed, the court declined to decide whether the plaintiffs' proposed "ordinary" uses of the range were valid.

The court also found a reasonable inference that the defect existed when the range left Samsung's control. Samsung designed, manufactured, and distributed the range; Stokes had never used it; and the recall for accidental-activation risk supported the inference that the knobs were in that condition from the outset.

Samsung argued that the plaintiffs relied on an impermissible stacking of inferences because the complaint did not identify any particular person or object that contacted the knobs. The court distinguished the Fourth Circuit authority on which Samsung relied, Maguire Financial, LP v. PowerSecure International, Inc., 876 F.3d 541 (4th Cir. 2017) as a securities fraud decision applying the Private Securities Litigation Reform Act's heightened pleading standard for scienter. That rule has no bearing where a court must draw all reasonable inferences in a plaintiff's favor. While a court need not accept unwarranted inferences, it must assume well-pleaded facts to be true.

Regarding causation, the court noted that Virginia requires only that the defect, in natural and continuous sequence unbroken by an efficient intervening cause, produce the injury, with a connection that moves the question out of conjecture and into legitimate inference. The sequence of events alleged, together with the many other reports of accidental activation, created a nonspeculative causal chain. Plaintiffs were not required at the pleading stage to rule out other plausible non-defect causes, nor to establish causation with such certainty as to exclude every other possible conclusion.

The negligence and implied warranty claims (Counts I and III), therefore survive. Because Samsung did not challenge the plaintiffs' alternative failure-to-warn theory, those counts may proceed on either a design defect or failure-to-warn basis. The court dismissed Count II, a standalone claim for "liability for defective product," as duplicative, noting that Virginia products liability actions can proceed only under negligence or implied warranty theories.

Claims against Best Buy. The consumer brought both a design defect claim and a failure to warn claim against Best Buy and its related entities. On the design defect claim, Best Buy argued that because it is a passive retailer, its duties are narrow and cannot be held liable. The court found that Virginia courts have not explicitly articulated a seller's duty to avoid distributing a negligently designed product. Virginia authority instead indicates that a seller's knowledge of a product's danger is essential: some courts have reasoned that a seller's duty falls beneath a manufacturer's because a seller that does not hold itself out as a manufacturer cannot reasonably avoid a design flaw, and sellers owe duties to warn of known or knowable dangers and to inspect or test when they know or have reason to know a product may be unreasonably dangerous. Because Virginia does not recognize a seller's duty to avoid negligent design, and the plaintiffs did not allege that Best Buy knew or should have known of the defect at the time of sale, the design defect claim failed.

On the failure to warn claim, the plaintiffs argued that Best Buy, like Samsung, had records identifying purchasers and could have alerted the consumer to the hazard. But the complaint did not allege that Best Buy knew of the defect before the recall, and the court found no allegation of how or why Best Buy would have known of the danger before the fire. Sellers, like manufacturers, are not insurers of product safety, and the duty to warn arises only where the defendant knows or has reason to know the product is dangerous. The court noted unsettled Virginia law on whether a post-sale duty to warn exists under a negligence theory, but reasoned that such a duty rests on superior knowledge of the product, which a seller would not be expected to maintain after a sale. Absent facts supporting an inference that Best Buy knew of the problem before the recall, the court could not conclude that selling the range without a warning was unreasonable.

The court therefore dismissed the design defect and failure to warn (Counts IV and V) against Best Buy and its related entities.

The case is No. 2:26-cv-00279-JKW-RJK.

Judge: Walker, J.

Attorneys: David Rosenblum (Rosenblum & Rosenblum LLC) for Spinnaker Insurance Co. Michael Richard Sklaire (Greenberg Traurig LLP) for Samsung Electronics America, Inc.

Companies: Spinnaker Insurance Co.; Samsung Electronics America, Inc.

MainStory: TopStory DesignManufacturingNews WarningsNews HouseholdProductsNews VirginiaNews