Law School Case Brief
KNAYSI v. A. H. ROBBINS Co. - 679 F.2d 1366 (11th Cir. 1982)
Equitable estoppel may arise in either of two ways. Equitable estoppel sufficient to bar the interposition of the statute of limitations results from representations or conduct which have induced a party to postpone bringing suit on a known cause of action, or from fraudulent concealment of an action which is unknown to a party.
Plaintiffs Anita and Ed Knaysi filed suit against defendants A. H. Robins, Inc. (Robins) and its insurer seeking recovery of damages resulting from injuries to Anita Knaysi allegedly caused by her use of the Dalkon Shield intrauterine device manufactured and distributed by Robins. Mrs. Knaysi became pregnant after insertion of the Dalkon Shield and in the first trimester suffered a spontaneous septic abortion of twin fetuses. The Knaysis' complaint sought recovery on the theories of negligence, breach of warranty, breach of implied contract, strict liability, fraud, conspiracy, and outrageous conduct. The district court resolved the case in Robins' favor on Robins' motion for summary judgment. The district court ruled that the fraud claim should not be treated separately from the products liability claim and was therefore barred by expiration of the three-year limitation applicable to products liability actions and that the doctrine of equitable estoppel was inapplicable in the case at bar.
Was summary judgment in favor of defendant manufacturer proper in a case alleging, inter alia, products liability, fraud, and negligence, where plaintiff patient alleged reliance on the manufacturer's representations regarding a contraceptive device and allegedly published information it knew to be false?
The United States Court of Appeals for the Eleventh Circuit held that there were genuine issues of material fact with respect to the application of the equitable estoppel doctrine which precluded summary judgment. Accordingly, the Court reversed the lower court's grant of summary judgment on behalf of appellees-defendants Robins and its insurer. The Court found that plaintiffs-appellants Knaysis had alleged that they relied on Robins' representations regarding a contraceptive device and that Robins allegedly published information about the device which it knew to be false. In addition, the Court found that the Knaysi's allegation that Robins knowingly suppressed damaging information about the device's danger was essential to make out a cause of action for products liability, breach of warranty, and other claims put forward by the Knaysis. The Court concluded that the allegations, when measured against the standards for equitable estoppel, were sufficient to invoke the application of the doctrine and that summary judgment was improper as there existed genuine issues of material fact. The Court remanded the case because genuine issues of material fact existed regarding the application of the equitable estoppel doctrine to a products liability action involving a contraceptive device.
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