## Facts

- Delmar H. Lewis, a minor, brought a diversity action in the U.S. District Court for the Western District of Pennsylvania against U.S. Slicing Machine Company, Inc.
- Lewis alleged he was injured in the course of his employment while using (including while cleaning/handling) a meat slicer.
- The complaint identified the slicer as a product designed and made (manufactured) by the defendant company.
- Lewis alleged that the company was negligent, careless, and reckless in the slicer’s design and/or manufacture and sought damages for resulting injuries.
- The complaint also asserted a product-based warranty theory, alleging breach of implied warranties of merchantability and/or fitness for a particular purpose arising from the slicer’s sale.
- The company moved to dismiss under Federal Rule of Civil Procedure 12, arguing that the complaint did not satisfy Federal Rule of Civil Procedure 8(a)(2) because it lacked sufficient factual detail about the specific defect or negligent acts.

## Issues

1. Whether a complaint alleging injury from a defendant-manufactured slicer, and generally alleging negligent design/manufacture (and related implied-warranty claims), states a “short and plain statement” sufficient to give notice under Rule 8(a)(2) and thus withstand a Rule 12 motion to dismiss.

## Decision

- The court denied the defendant’s motion to dismiss.
- The court held that the complaint met Rule 8(a)(2) because it provided fair notice of the nature of the claims and the grounds on which they rested.
- The court indicated that demands for technical or evidentiary detail about the precise defect or specific negligent conduct were matters for discovery rather than a basis for dismissal at the pleading stage.

## Legal Principles

- Rule 8(a)(2) requires a short and plain statement showing the pleader is entitled to relief; it does not require detailed evidentiary facts in the complaint.
- A complaint is sufficient if it gives the defendant fair notice of what the claim is and the general basis for it, so the defendant can frame a response.
- In product-injury litigation, identifying the product, the defendant’s connection to it (manufacturer/designer), the occurrence of an injury in connection with the product, and the legal theories of recovery (such as negligence and implied warranty) can be enough to satisfy notice pleading.
- A Rule 12 motion tests the legal sufficiency of the pleadings, not whether the plaintiff has already stated all technical details that will later be proved; missing particulars are ordinarily addressed through discovery and later case-management tools.

## Conclusion

In *Lewis v. U.S. Slicing Machine Co., Inc.*, the court held that a diversity complaint alleging injury from a slicer made by the defendant, supported by general allegations of negligent design/manufacture and breach of implied warranties, satisfied Rule 8(a)(2)’s notice-pleading standard; therefore, dismissal under Rule 12 for lack of additional factual detail was not warranted.


Lewis v. U.S. Slicing Machine Co., Inc., 311 F.Supp. 139 (1970)