Products Liability Law Daily Wrap Up, JURISDICTION—TOOLS AND HARDWARE—E.D. Cal.: Chainsaw maker subject to jurisdiction but wins dismissal of injured consumer’s claims in explosion case, (Oct 6, 2026)

By Pankhuri Bhatnagar, B.A. LL.B.

The consumer’s strict liability and negligence claims were dismissed for failure to identify a product defect but leave to amend was granted as to all claims.

In an action brought against a chainsaw manufacturer by a man who allegedly sustained severe burn from an exploding chainsaw, a federal district court in California denied the manufacturer’s motion to dismiss for lack of personal jurisdiction but dismissed all claims on merits. The manufacturer was subject to jurisdiction as the subject chainsaw was marketed, distributed, and sold in California before it was discontinued and it was reasonably foreseeable that injuries could arise years later. The consumer failed to identify which aspect of the gas cap or fuel system was defective, allege a manufacturing deviation, allege the need for a warning, and a need to recall or retrofit the subject product (Haverty v. STIHL Inc., No. 2:25-cv-03043-DAD-DMC (E.D. Cal. Sept. 28, 2026)).

Background. In September 2023, a California resident was using a STIHL MS 290 chainsaw to cut wood outside his home when it suddenly exploded, causing his body and clothing to catch fire and resulting in burns to approximately 27% of his body surface area. He brought suit against STIHL Incorporated and its related entities, arguing that the chainsaw’s gas cap or fuel system was defectively designed and caused his injuries while he was using it as intended or in a reasonably foreseeable manner. His complaint alleged claims for strict products liability, negligence, and negligent products liability theories. STIHL moved to dismiss for lack of specific personal jurisdiction and for failure to state a claim.

Personal jurisdiction. STIHL was a Delaware corporation with its principal place of business in Virginia. To establish specific personal jurisdiction over it, the consumer needed to show that it purposefully availed itself of the forum market, his claims arose out of or related to that form activity, and the exercise of jurisdiction was reasonable. The manufacturer did not challenge the first or third prongs, acknowledging that its shipment of STIHL-branded products to its California branch and sales through independent California retailers established minimum contacts with the state, and waiving any reasonableness arguments. As for claim relatedness, the parties cited Ford Motor Co. v. Montana Eighth Judicial District Court, 592 U.S. 351 (2021), which held that a claim may relate to forum contacts even without direct causation when a manufacturer systematically serves the forum market for the same type of product that allegedly injured the consumer there.

The court observed that the facts of the case at bar were overwhelmingly similar to Ford—the subject chainsaw (1) was not designed, manufactured, distributed, or sold in California; (2) malfunctioned in California; (3) was not initially sold to the claimant; and (4) the manufacturer admitted that its distribution and sale of STIHL-branded products in California created minimum forum contacts. Moreover, STIHL “should have foreseen the risk” that selling outdoor power equipment in California might still cause injuries years after the product’s discontinuation. Thus, the claims related to its California-based contacts and the Rule 12(b)(2) motion was denied.

Design defect. This claim requires a showing that a defective product was placed on the market and that defect caused the alleged injury. California recognizes both the consumer-expectation and risk-benefit tests for design defects. However, the complaint did not identify any specific aspect of the gas cap or fuel system that made the design defective. It merely alleged that the chainsaw failed the two tests and was unreasonably dangerous. Those conclusory allegations were insufficient to establish a plausible design defect, Lucas v. City of Visalia, 726 F. Supp. 2d 1149, 1155 (E.D. Cal. 2010), and the strict-liability claim was dismissed without reaching the causation argument.

Negligent products liability. The complaint alluded to all three theories of negligence: design defect, manufacturing defect, and failure to warn. The negligent design-defect theory failed for the same reasons as the strict-liability claim. The manufacturing-defect theory did not allege how the particular chainsaw deviated from STIHL’s intended design or from identical products, relying instead on conclusory statements that it was improperly manufactured. The failure-to-warn theory likewise failed. California law requires allegations showing that the manufacturer knew or should have known of the danger and that its failure to warn substantially contributed to the injury. The complaint merely alleged that STIHL knew or should have known the chainsaw was defective and dangerous. Because those allegations provided no factual basis from which knowledge could reasonably be inferred, the court dismissed the warning theory without reaching the remaining elements.

Negligence and recall. The general negligence claim substantially duplicated the negligent products-liability claim and therefore failed for the same reasons. The additional allegation that STIHL negligently failed to recall or retrofit the chainsaw also failed because California recognizes such a duty only when a manufacturer has post-sale knowledge of a dangerous defect or a shift in industry standards placing it on notice. Roberts v. Electrolux Home Prods., Inc., No. 8:12-cv-1644-CAS-VBK (C.D. Cal. Mar. 4, 2013). As the court held, the consumer did not plausibly allege that STIHL knew or should have known of the purported defect. The court accordingly dismissed all claims but allowed leave to amend since the pleading deficiencies could conceivably be cured by additional and more detailed allegations. Nat’l Council of La Raza v. Cegavske, 800 F.3d 1032, 1041 (9th Cir. 2015). The motion to transfer was denied as moot.

The case is No. 2:25-cv-03043-DAD-DMC.

Judge: Drozd, D.

Attorneys: Dan B. Yakobian (DBY Law) for Steven Haverty. Justin D. Howard, PHV (McGuireWoods LLP) for Stihl Inc.

Companies: Stihl Inc.

MainStory: TopStory CourtDecisions JurisdictionNews ToolsHardwareNews CaliforniaNews