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Obenauer v. Liberty Mut. Ins. Co.

United States Court of Appeals, Eighth Circuit
Jul 10, 1990
908 F.2d 316 (8th Cir. 1990)

Summary

concluding that an insurer providing safety services to a manufacturer was not liable under Section 324A to the user of a manufactured product because the insurer did not "replace" the manufacturer's duty to design a safe product

Summary of this case from Padilla v. Hunter Douglas Window Coverings, Inc.

Opinion

No. 89-5408ND.

Submitted May 16, 1990.

Decided July 10, 1990.

Gary Hamblet, Los Angeles, Cal., for appellant.

Mitchell Mahoney, Minot, N.D., for appellee.

Appeal from the United States District Court for the District of North Dakota.

Before FAGG, Circuit Judge, BRIGHT, and HENLEY, Senior Circuit Judges.


The district court granted summary judgment to Liberty Mutual Insurance Company (Liberty) after Edward Obenauer brought this product liability action against Liberty. Obenauer appeals, and we affirm.

Edward Obenauer severely injured his right hand while operating a baling machine designed by Vermeer Manufacturing Company (Vermeer). At the time Vermeer designed the baler, Liberty provided Vermeer with insurance and accident prevention services. Obenauer claims that because Liberty regularly inspected the baler and provided design advice to Vermeer, Liberty is liable to Obenauer for his injuries.

The courts of North Dakota have never decided the question of whether an insurer that provides accident protection services is liable to third parties, and the district court thus adopted the Restatement (Second) of Torts § 324A (1965) as North Dakota law. See Patch v. Sebelius, 349 N.W.2d 637, 642 (N.D. 1984) (applying section 324A to impose liability on road construction contractor). Neither Obenauer nor Liberty disputes the district court's choice of section 324A, and we defer to the District Court of North Dakota when it decides a question of state law that North Dakota state courts have not yet addressed. Kloster Co. v. Michigan Mut. Ins. Co., 882 F.2d 1308, 1310 (8th Cir. 1989).

Instead, Obenauer asserts the district court committed error in its application of section 324A. The district court held Liberty's inspections did not replace Vermeer's duty to Obenauer to design a safe product and did not constitute an "undertaking" under section 324A. Other courts have decided the question of insurer liability similarly. See, e.g., Davis v. Liberty Mut. Ins. Co., 525 F.2d 1204, 1207-08 (5th Cir. 1976); Rick v. RLC Corp., 535 F. Supp. 39, 46-47 (E.D.Mich. 1981); Smith v. Allendale Mut. Ins. Co., 303 N.W.2d 702, 710-12 (Mich. 1981). Because the district court's interpretation of Restatement § 324A is not "`fundamentally deficient in analysis or otherwise lacking in reasoned authority,'" Turley Martin Co. v. Gilman Paper Co., 905 F.2d 235, 238 (8th Cir. 1990) (quoting Pershern v. Fiatallis North America, 834 F.2d 136, 138 (8th Cir. 1987)), we decline to second-guess the court's formulation of North Dakota law.

We thus affirm the judgment of the district court.


Summaries of

Obenauer v. Liberty Mut. Ins. Co.

United States Court of Appeals, Eighth Circuit
Jul 10, 1990
908 F.2d 316 (8th Cir. 1990)

concluding that an insurer providing safety services to a manufacturer was not liable under Section 324A to the user of a manufactured product because the insurer did not "replace" the manufacturer's duty to design a safe product

Summary of this case from Padilla v. Hunter Douglas Window Coverings, Inc.

concluding that an insurer providing safety services to a manufacturer was not liable under Section 324A to the user of a manufactured product because the insurer did not “replace” the manufacturer's duty to design a safe product

Summary of this case from Knife River Co-S v. Hinojosa

concluding that an insurer providing safety services to a manufacturer was not liable under Section 324A to the user of a manufactured product because the insurer did not "replace" the manufacturer's duty to design a safe product

Summary of this case from Knife River Corp.-S. v. Hinojosa
Case details for

Obenauer v. Liberty Mut. Ins. Co.

Case Details

Full title:EDWARD OBENAUER, APPELLANT, v. LIBERTY MUTUAL INSURANCE CO., APPELLEE

Court:United States Court of Appeals, Eighth Circuit

Date published: Jul 10, 1990

Citations

908 F.2d 316 (8th Cir. 1990)

Citing Cases

Plank v. Union Elec. Co.

The Eighth Circuit held that an insurer providing safety services to a manufacturer was not liable to the…

Padilla v. Hunter Douglas Window Coverings, Inc.

at 1156-57. See also Obenauer v. Liberty Mat. Ins. Co., 908 F.2d 316, 317 (8th Cir. 1990) (concluding that an…