PHILADELPHIA - Allstate disagreed with an Aug. 3 ruling in its cases against Electrolux Home Products. but a Philadelphia federal judge has ruled against its motion for reconsideration anyway.
However, the court agreed to consolidate three of its 86 claims. The new opinion was filed on Oct. 3 with the U.S. District Court for the Eastern District of Pennsylvania. Judge Joseph Leeson delivered the ruling.
Allstate sued Electrolux after it received 86 separate claims about the company’s clothes dryers. The dryers caught fire and caused damage that Allstate then had to cover. Electrolux asked the complaint be dismissed, or, if that was impossible, to sever the 86 claims and dismiss those that failed to “satisfy the amount in controversy required for diversity actions.”
The court chose the latter route. It “severed the claims, dismissed those claims with amounts in controversy less than the statutory minimum for federal diversity jurisdiction, and transferred those claims that did not originate from within the Eastern District of Pennsylvania.”
Leeson notes that motions for reconsideration should be granted sparingly. It’s in the interest of the court for judgments to be final. Allstate failed to meet its burden of proof. In order for a motion for reconsideration needs to use one of three arguments: “(1) an intervening change in the controlling law; (2) the availability of new evidence that was not available when the court granted the underlying motion; or (3) the need to correct a clear error of law or fact or to prevent manifest injustice.”
Allstate’s request to join its three Eastern District of Pennsylvania claims into a single complaint was granted. According to the court, the benefits are “obvious.” The cases are very similar. They each involve Electrolux dryers and Pennsylvania law.