## Facts

- Nineteen federal products-liability actions in fourteen districts alleged injuries or deaths linked to multi-piece truck wheel (rim and tire) assemblies.
- In eighteen actions, the alleged failure occurred when a multi-piece rim assembly separated under pressure during tire inflation, mounting of an inflated wheel, or removal of an inflated wheel, causing explosive separation.
- In one action, a rim allegedly separated during vehicle operation, causing loss of control and a collision.
- Firestone Tire & Rubber Co. (14 actions) and Goodyear Tire & Rubber Co. (8 actions) were principal defendants; either Firestone or Goodyear was named in every action, with additional rim makers and other peripheral defendants also sued.
- Plaintiffs commonly alleged design and manufacturing defects and inadequate warnings for use, maintenance, and servicing of the rims; some alleged concealment or misrepresentation of safety information to governmental authorities.
- The actions were at different procedural stages; some parties supported centralization, while others objected based on individualized facts and advanced discovery in certain cases.
- Motions sought transfer for coordinated or consolidated pretrial proceedings under 28 U.S.C. § 1407.

## Issues

1. Whether the actions involved one or more common questions of fact sufficient for transfer under 28 U.S.C. § 1407.
2. Whether centralization would serve the convenience of parties and witnesses and promote the just and efficient conduct of the litigation.
3. Whether any actions should be excluded from transfer because their posture made transfer inefficient.
4. Which district was the most appropriate transferee forum for coordinated pretrial proceedings.

## Decision

- The Panel found the actions shared substantial common questions of fact and satisfied § 1407’s requirements for coordinated pretrial proceedings.
- The Panel transferred most actions to the Western District of Missouri for coordinated pretrial proceedings.
- The Panel excluded the Oregon and Mississippi actions from transfer because discovery in those cases was at an advanced stage and transfer would provide little benefit.
- The Panel selected the Western District of Missouri as the transferee district based on central location and the assigned judge’s experience with related litigation.

## Legal Principles

- Under 28 U.S.C. § 1407(a), civil actions pending in different districts may be transferred for coordinated or consolidated pretrial proceedings when they share one or more common questions of fact and transfer will serve convenience and promote just and efficient conduct.
- Complete factual identity across actions is not required; substantial overlapping factual questions can justify centralization.
- Centralization is favored when it can reduce duplicative nationwide discovery and limit inconsistent pretrial rulings on recurring issues (including common expert and corporate discovery disputes).
- Individualized issues (accident-specific causation, fault, damages, and peripheral defendants) do not bar centralization and may be managed through tailored pretrial organization or addressed later in transferor courts.
- The Panel may exclude particular actions from an MDL when their advanced procedural posture makes transfer inefficient.

## Conclusion

The Panel centralized most multi-piece rim products-liability actions in the Western District of Missouri because common factual disputes about rim design, industry knowledge of separation risks, and warning adequacy made coordinated discovery and consistent pretrial rulings efficient, while excluding two advanced cases where transfer would not materially improve efficiency.


In re Multi-Piece Rim Prods. Liab. Litig., 464 F. Supp. 969 (J.P.M.L. 1979)