Sattelmyer v. Covidien, L.L.C.

Citations

• 2026 Ohio 527

Syllabus

PRODUCT LIABILITY – CIV.R. 12(B)(6) – NOTICE PLEADING – CIV.R. 8: Because plaintiff pled sufficient facts to support her manufacturing-defect and design-defect claims under the Ohio Product Liability Act, R.C. 2307.71 et seq., the trial court erred by applying the heightened federal pleading standard and granting defendant-manufacturers' motion to dismiss plaintiff's product liability claims. However, because plaintiff failed to articulate facts that would provide defendants with adequate notice of her nonconformance with representations and inadequate warning or instructions claims, the trial court did not error in dismissing these claims under Civ.R. 12(B)(6). Furthermore, plaintiff's failure to sufficiently allege facts relevant to some of the defendants named in her complaint supported dismissal of all product liability claims against these parties. Judgment affirmed in part and reversed in part; cause remanded.