Case Explained: Berkley National Insurance Company, a/s/o Lakes Community Cooperative v. Broan-Nutone, LLC

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-08-11 The eighth-circuit affirmed the district court’s grant of summary judgment to Broan-Nutone, LLC, holding that Berkley National Insurance Company failed to present sufficient evidence to establish a manufacturing defect claim under Minnesota law. The court applied the standard for strict liability manufacturing defect claims, which requires a plaintiff to prove by a preponderance of the evidence that (1) the product was in a defective condition unreasonably dangerous for its intended use, (2) the defect existed at the time the product left the defendant’s control, and (3) the defect proximately caused the injury. While acknowledging that plaintiffs may rely on circumstantial evidence rather than specific deviations from a flawless product, the court emphasized that such evidence must allow a reasonable inference that the defect existed when the product was distributed, without requiring speculation. The court found Berkley’s expert testimony insufficient because it failed to demonstrate that the alleged malfunction—overheating due to a failed thermal protection device or insulation by dust and lint—was present when Broan manufactured and sold the fan. Given that the fan had been installed more than ten years prior to the fire, creating a substantial opportunity for mishandling, misuse, or environmental accumulation of debris, the evidence did not rule out the possibility that the defect developed after the product left Broan’s control. Consequently, the practical consequence is that the district court’s ruling stands, dismissing Berkley’s claim and leaving Broan-Nutone without liability for the fire damages. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.