Stiner v. Amazon.com, Inc. (Slip Opinion)

Stiner v. Amazon.com, Inc. (Slip Opinion)

The statutory phrase "otherwise participates in the placing of a product in the stream of commerce" is limited by the specific enumerated actions and requires some exercise of control over the product; Amazon did not exercise the requisite control (it did not manufacture, package, label, possess, or ship the...

Source-derived case information.

Citation
162 Ohio St. 3d 128; 164 N.E.3d 394; 2020 Ohio 4632
Parties
Appellant / Plaintiff: Dennis Stiner, Administrator of the Estate of Logan Stiner; Appellee / Defendant: Amazon.com, Inc.
Court
Ohio Supreme Court
Jurisdiction
United States
Judgment Date
1 October 2020
Case Number
2019-0488
Procedural Posture
Products Liability / Torts / Appeal to Supreme Court of Ohio Following Grant of Summary Judgment
Outcome
Judgment affirmed; summary judgment for Amazon affirmed
Legal Topics
Ohio Products Liability Act Interpretation, Definition of Supplier, Stream of Commerce, Control Over Product, Strict Liability
Source Language
english
Torts Products Liability Statutory Interpretation E Commerce Liability Ohio Products Liability Act Interpretation Definition of Supplier Stream of Commerce Control Over Product +1 more

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Parties

Dennis Stiner, Administrator of the Estate of Logan Stiner

Appellant / Plaintiff

Amazon.com, Inc.

Appellee / Defendant

Procedural Posture

Products Liability / Torts / Appeal to Supreme Court of Ohio Following Grant of Summary Judgment

Legal Issues

  1. 1 Whether Amazon constitutes a "supplier" under R.C. 2307.71(A)(15)(a)(i) by "otherwise participating in the placing of a product in the stream of commerce"
  2. 2 Whether the catchall phrase "otherwise participates" includes conduct different in kind from sale, distribution, preparation, packaging or labeling
  3. 3 Whether policy considerations supporting strict liability permit expanding supplier status to an internet marketplace operator

Ratio Decidendi

The statutory phrase "otherwise participates in the placing of a product in the stream of commerce" is limited by the specific enumerated actions and requires some exercise of control over the product; Amazon did not exercise the requisite control (it did not manufacture, package, label, possess, or ship the product) and therefore is not a "supplier" under R.C. 2307.71(A)(15)(a)(i), so summary judgment for Amazon was proper.

Court Disposition

Judgment affirmed; summary judgment for Amazon affirmed

Orders

  • Affirmed judgment of the Ninth District Court of Appeals
  • Summary judgment granted to Amazon on appellant's product-liability claims