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Nevada Supreme Court Affirms Dismissal of Battery Explosion Suit

The Nevada Supreme Court affirmed a district court's dismissal of a products liability lawsuit against Korean battery manufacturer LG Chem for lack of personal jurisdiction. Nevada resident Roberto Franceschi sued after suffering severe burns when a lithium-ion battery exploded in his pocket.

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4 min readcourtlistener
Seal of the Nevada Supreme Court

Case Information

Case No.:
No. 87802

Key Takeaways

  • Nevada Supreme Court affirmed dismissal of battery explosion lawsuit against LG Chem for lack of personal jurisdiction
  • Nevada resident Roberto Franceschi suffered severe burns when lithium-ion battery exploded in his pocket
  • Court found plaintiff's claims insufficiently related to LG Chem's contacts with Nevada

The Nevada Supreme Court affirmed a lower court's dismissal of a products liability lawsuit filed by a Nevada resident against Korean battery manufacturer LG Chem Ltd. and its Delaware-incorporated subsidiary LG Chem America Inc., ruling the state lacked personal jurisdiction over the defendants.

Roberto Franceschi, a Nevada resident, filed the lawsuit after suffering severe burns when a lithium-ion battery manufactured by LG Chem exploded while in his front pocket. Franceschi sued both LG Chem Ltd., described in court documents as a foreign company, and LG Chem America Inc., a Delaware corporation, seeking damages for products liability in Nevada state court.

The case, designated as No. 87802, was filed December 18, 2025, in the Nevada Supreme Court following an appeal from the Eighth Judicial District Court in Clark County. Judge Maria Gall presided over the original district court proceedings.

The district court granted the defendants' motions to dismiss the case for lack of personal jurisdiction, finding that Franceschi's claims were insufficiently related to LG's contacts with Nevada. The lower court certified its order as final under Nevada Rule of Civil Procedure 54(b), allowing Franceschi to immediately appeal the jurisdictional ruling.

Personal jurisdiction determines whether a court has the authority to exercise power over a particular defendant. For out-of-state or foreign defendants, courts must establish sufficient minimum contacts between the defendant and the forum state to satisfy due process requirements. The Supreme Court's opinion indicates this case centered on whether LG Chem's business activities in Nevada were substantial enough to justify the state's exercise of jurisdiction over the Korean manufacturer.

The case was heard by Justices Pickering, Cadish, and Lee, with Justice Lee writing the court's opinion. The opinion begins by noting that the case presents a question of personal jurisdiction, highlighting the procedural focus of the appeal rather than the underlying merits of Franceschi's products liability claims.

Franceschi was represented by attorneys from Claggett & Sykes Law Firm, including David P. Snyder, Sean K. Claggett, Brian Blankenship, Micah S. Echols, and Charles L. Finlayson, all based in Las Vegas. Additional counsel came from Davis Law Group PLLC, with David S. Davis also representing the plaintiff.

The defendants were represented by Lewis Brisbois Bisgaard & Smith LLP, with Wendy S. Dowse from the firm's Indian Wells, California office and Laureen Frister from Las Vegas handling the case.

The ruling demonstrates the challenges plaintiffs face when suing foreign manufacturers in state courts, particularly when the connection between the defendant's activities and the forum state may be limited. Personal jurisdiction issues frequently arise in products liability cases involving international companies, as injured parties often prefer to sue in their home jurisdictions for convenience and strategic advantages.

Lithium-ion battery explosions have become an increasingly prevalent safety concern as these power sources are used in everything from smartphones and laptops to electric vehicles and power tools. The batteries can overheat, swell, and potentially explode or catch fire due to manufacturing defects, damage, or improper charging.

LG Chem is one of the world's largest chemical companies and a major manufacturer of lithium-ion batteries for various consumer and industrial applications. The company supplies batteries to numerous electronics manufacturers and automotive companies globally.

The Nevada Supreme Court's affirmation of the dismissal means Franceschi will need to pursue his claims in a different forum where personal jurisdiction over LG Chem can be properly established. This could include federal court or courts in states where LG Chem conducts more substantial business activities.

The decision also underscores the importance of establishing proper venue and jurisdiction before filing products liability lawsuits against international manufacturers. Plaintiffs' attorneys must carefully analyze a defendant company's business contacts with potential forum states to avoid dismissal on jurisdictional grounds.

For Nevada practitioners, the ruling serves as a reminder that the state's long-arm jurisdiction has limits, particularly when dealing with foreign corporations whose primary business activities occur outside Nevada's borders.

The case highlights ongoing tensions in the American legal system between providing injured parties access to convenient forums and respecting constitutional limitations on state court authority over out-of-state and foreign defendants. As global commerce continues to expand, courts regularly grapple with determining the appropriate boundaries of personal jurisdiction in an interconnected economy.

While the specific details of LG Chem's Nevada business contacts were not detailed in the available court documents, the affirmation suggests the Supreme Court found the district court's jurisdictional analysis legally sound under current precedent governing personal jurisdiction over foreign corporations.

Topics

personal jurisdictionproducts liabilitylithium-ion battery explosionmotion to dismissstream of commerce

Original Source: courtlistener

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