## Facts

- Daniel Fassett purchased a Sears Craftsman ZT 7000 zero-turn riding lawnmower in 2007.
- While mowing in May 2013, the mower sputtered; Fassett drove it into his garage, turned it off, and lifted the seat to inspect the fuel system.
- Fassett observed the gasoline tank appeared expanded; when he loosened the gas cap, gasoline sprayed out, ignited, and caused severe burns.
- Plaintiffs sued multiple entities associated with the mower’s design, manufacture, and component supply, asserting product-liability and negligence theories, including punitive damages and loss of consortium.
- Earlier in the case, the court dismissed implied-warranty and negligent-infliction-of-emotional-distress claims but allowed the punitive-damages theory to proceed.
- During discovery, plaintiffs moved to compel production of information about alternative gas-cap designs and alternative mower/fuel-system layouts beyond the exact configuration on Fassett’s mower.
- The dispute required application of Federal Rule of Civil Procedure 26(b)(1) (post-2015 amendments) regarding relevance and proportionality.

## Issues

1. Under Rule 26(b)(1), what scope of discovery into alternative designs is relevant and proportional in a products-liability case involving a specific fuel-system design?
2. How should similarity, functional interchangeability, and burden affect whether plaintiffs may obtain discovery about other gas caps, fuel tanks, and mower models/layouts?

## Decision

- The court granted the motions to compel in part and denied them in part.
- The court ordered discovery for alternative designs and components closely similar to, or functionally interchangeable with, the fuel-system components at issue (including certain “free-venting” gas-cap designs).
- The court limited or denied discovery into more remote mower layouts, models, and configurations where the connection to the alleged defect was attenuated and the burden outweighed the likely benefit.
- The court treated proportionality as a central constraint, applying the Rule 26(b)(1) factors to tailor discovery.

## Legal Principles

- Rule 26(b)(1) permits discovery of nonprivileged matter that is relevant and proportional to the needs of the case; proportionality is assessed by the issues’ importance, amount in controversy, access to information, resources, importance of discovery to resolving issues, and whether burden outweighs benefit.
- In alternative-design discovery, similarity to the allegedly defective design is the primary driver of discoverability; the more similar the alternative, the broader the permissible discovery.
- Functional equivalence and interchangeability (whether an alternative component can serve the same function in a similar system) support discoverability.
- Comparable safety-testing requirements and whether the request concerns an interchangeable component versus a distinct system inform proportionality.
- A requesting party’s record support (including knowledgeable witness or expert testimony linking the alternative design to the contested design) can justify discovery; speculative or sweeping requests may be curtailed.

## Conclusion

The court applied amended Rule 26(b)(1) to impose similarity-based, proportional limits on alternative-design discovery, allowing targeted production for closely related and functionally interchangeable fuel-system designs while restricting discovery into more distant product variations whose burden outweighed their likely value.


Fassett v. Sears Holdings Corp., 319 F.R.D. 143 (M.D. Pa. 2017)