Philadelphia Partners Ty Havey and Cathy Slavin, Sacramento Senior Counsel Jennifer Paez, and Associate Erica Briggs successfully defended a leading global manufacturer of premium paint and coating products in a high-stakes case brought under the Federal Hazardous Substances Act (FHSA), 15 U.S.C. § 1261 et seq. On November 4, 2024, the United States District Court for the Northern District of California granted summary judgment and dismissed all claims against the firm’s client.
The case, brought by a subrogating insurance carrier and its policyholders—a vineyard and winery—arose from a total loss structure fire in Sonoma County. The plaintiffs alleged that discarded rags soaked with the client’s wood stain product spontaneously combusted due to inadequate labeling. The GRSM team denied the spontaneous combustion claim and argued that the FHSA, which governs product labeling for hazardous substances, preempted plaintiffs’ claims for additional warnings about spontaneous combustion.
The District Court adopted GRSM’s arguments in full, holding that the FHSA does not require specific warnings for spontaneous combustion and that any additional warning claims were preempted under the FHSA’s express preemption clause.
This victory aligns with a September 23, 2021, decision secured by Havey and his team in a similar case and contributes to a growing body of federal case law affirming the preemption of spontaneous combustion warning claims under the FHSA.
Contact the attorneys involved in this decision for assistance with similar matters.