James v. Meow Media, Inc., 300 F.3d 683 (6th Cir. 2002) (full-text).
Factual Background Edit
On December 1, 1997, Michael Carneal shot several of his fellow students, killing three and wounding many others. Parents of the students who were killed sued companies that produced or maintained video games, movies, and internet websites which allegedly desensitized the classmate to violence and caused his actions, asserting claims for negligence, product liability, and violations of the Racketeer Influenced and Corrupt Organizations Act (RICO).
Trial Court Proceedings Edit
The trial court granted defendants' motion to dismiss for failure to state a claim on which relief could be granted. The trial court held that Carneal's actions were not sufficiently foreseeable to impose a duty of reasonable care of the defendants with regard to Carneal's victims. The trial court held that even if such a duty existed, Carneal's actions constituted a superseding cause of the victims' injuries, defeating the element of proximate causation, not withstanding the defendants' negligence.
The court also determined that the thoughts, ideas, and messages supplied by the defendants' movies, video games, and internet sites were not "products" for purposes of Kentucky law, and thus the defendants could not be held strictly liable for any alleged defects. Last, the court held that Plaintiffs had not stated a viable RICO claim against the defendant internet firms because it had failed to identify an organization that had been corrupted and had failed to show any injury to “business or property” as required for standing under RICO.
Appellate Court Proceedings Edit
The appellate court held that, under Kentucky law, the existence of a duty of care to plaintiff and its underlying foreseeability inquiry is a pure question of law for the court. The appellate court also held that, under Kentucky law, the defendants did not owe a duty of care to the students who were killed by the classmate. Last, the court affirmed that video games, movies, and websites were not "products" for purposes of strict products liability.