## Facts

- Sierocinski was injured when a dynamite cap prematurely exploded while he was “crimping” it as part of its ordinary use.
- The cap was manufactured by E.I. Du Pont de Nemours & Co. and supplied to Sierocinski by his employer.
- Sierocinski alleged Du Pont negligently manufactured and distributed the cap so it could not withstand crimping, which Du Pont knew the cap would undergo.
- He further alleged Du Pont distributed a cap constructed to explode upon being crimped, without warning, despite knowledge it would be crimped.
- The district court required a more definite statement under Rule 12(e), then struck the amended complaint for failing to plead “any specific act of negligence,” and dismissed the action.

## Issues

1. Whether the amended negligence complaint stated a claim under Federal Rule of Civil Procedure 8(a)(2) despite not identifying the precise defect or specific internal acts causing the cap to explode.
2. Whether Rule 8 requires a negligence plaintiff to plead detailed evidentiary facts (such as improper ingredients, faulty inspection, warranty, or misrepresentation theories) rather than general factual allegations giving notice of the claim.

## Decision

- The Third Circuit reversed the order striking the amended complaint and the judgment dismissing the action.
- The court held the amended complaint sufficiently stated a claim for negligence under Rule 8’s “short and plain statement” requirement.
- The case was remanded for further proceedings.

## Legal Principles

- Rule 8(a)(2) requires only a short, plain statement showing entitlement to relief; it does not require technical or highly particularized negligence pleading.
- Under Rule 8(e)(1) and Rule 8(f), pleadings should be simple, concise, direct, and construed to do substantial justice.
- A plaintiff need not plead evidence; it is enough to allege negligent manufacture and distribution causing injury in the product’s expected use.
- The official forms referenced by the Rules illustrate the minimal specificity required and support rejecting demands for detailed allegations of the precise defect.

## Conclusion

The Third Circuit held that allegations that a manufacturer negligently made and distributed a dynamite cap that exploded during an anticipated step in ordinary use provided adequate notice under Rule 8, making dismissal for lack of detailed “specific acts of negligence” improper.


Sierocinski v. E.I. Du Pont de Nemours & Co., 103 F.2d 843 (3d Cir. 1939)