The Firm won summary judgment in the United States District Court for the District of New Jersey on behalf of its client, a leading manufacturer of premium consumer and industrial paint and coatings products, dismissing claims that the label of one of its wood stain products failed to adequately warn about a purported spontaneous combustion risk.
Plaintiffs claimed that a fire allegedly caused by spontaneous combustion associated with the stain could have been avoided had the product label more prominently and conspicuously warned about spontaneous combustion. We denied that the fire was caused by spontaneous combustion and argued that, in any event, plaintiffs could not maintain their warning claims because the Federal Hazardous Substances Act (FHSA), which governed the wood stain, preempted claims inconsistent with it and did not require that products governed by it bear spontaneous combustion warnings—even assuming a spontaneous combustion risk existed. Thus, we pointed out, our client went above and beyond what it was legally obligated to do by including a spontaneous combustion warning at all.
The District Court adopted our arguments in full, holding that (1) for products, like the client’s wood stain, governed by the FHSA, “the law could not be clearer that a plaintiff cannot bring a failure-to-warn claim based on state-law theories that the label should have included additional warnings not required under the FHSA,” and (2) “no reasonable jury could find that the [wood stain] label violates the FHSA by failing to identify the risk of spontaneous combustion,” because spontaneous combustion is not required to be warned about under the FHSA.
