State Farm V Tesla
State Farm V Tesla
State Farm V Tesla
COMPLAINT
to as "STATE FARM"), complain of Defendant TESLA, INC., formerly known as Tesla Motors,
Inc., a Delaware Corporation ("TESLA") and for its complaint, alleges the following:
The Parties
1. STATE FARM is a corporation organized under the laws of Illinois with its
2. At all relevant times, STATE FARM was engaged in the business of issuing
insurance policies for homes and automobiles located throughout the United States, including the
State of Indiana.
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3. Upon information and belief, at all relevant times, Defendant Tesla was a
corporation organized under the laws of Delaware, with its current principal place of business in
Austin, Texas.
4. At all relevant times, Defendant Tesla was engaged in the business of designing,
5. At all relevant times, Defendant Tesla distributed, marketed and sold its
automobiles throughout the United States, including Indiana, using a network of Authorized or
Certified Dealerships.
referred to as the "the Sencaj Family") were the owners of real and personal property located at
10730 Torrey Pines Circle, Carmel, Indiana 46032 (hereinafter referred to as "the Sencaj
residence").
7. At all relevant times, STATE FARM issued a policy of insurance to the Sencaj
Family, which provided indemnification and reimbursement for fire related damage to the Sencaj
residence and its contents, the vehicles, as well as additional living expenses incurred by the Sencaj
8. At all relevant times, the Sencaj Family owned a 2016 Tesla Model S bearing
9. At all relevant times, the Tesla was located within the attached garage of the Sencaj
residence.
10. Jurisdiction is proper within the federal court system pursuant to 28 U.S.C 1332
based upon diversity of citizenship. An actual controversy of a justiciable nature exists between
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STATE FARM and the Defendant. Plaintiff and Defendant are fully diverse as they have neither
their places of incorporation nor principal place of business in common. STATE FARM is an
Illinois Corporation with its principal place of business within Illinois. Tesla is a Delaware
Corporation with its principal place of business in Texas. Tesla’s prior principal place of business
at the time of the sale of the vehicle was in California. The amount in controversy exceeds
$75,000.00.
11. This court has personal jurisdiction over Tesla as it knowingly distributes products
to the State of Indiana for purchase by consumers in Indiana, purposefully availing itself to the
laws of Indiana.
subject to personal jurisdiction in this judicial district, and because a substantial part of the events
and activities giving rise to STATE FARM’s claims occurred in this judicial district. The events
giving rise to the litigation took place in Hamilton County, Indiana. The property at issue is located
in Carmel, Indiana, within Hamilton County part of the Southern District of Indiana, the
13. Upon information and belief, Defendant Tesla manufactured, designed, assembled,
14. Upon information and belief, in 2016, Defendant Tesla placed the Tesla into the
stream of commerce with the purpose, expectation and intent the Tesla would reach consumers, in
that condition.
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The Fire
16. From the time of purchase, the Sencaj Family used the Tesla vehicle for the normal
17. Upon information and belief, the Sencaj family maintained the Tesla pursuant to
Defendant Tesla’s maintenance and service recommendations and all such service was performed
by Tesla.
18. On February 17, 2020, a fire erupted from the Tesla and spread to the Sencaj
residence as well as the personal property located within the Sencaj residence. (hereinafter referred
to as "the Fire").
19. The day of the Fire, the Sencaj family drove the Tesla to complete various errands.
They returned to the home and parked the Tesla in the attached garage, plugging it in to the electric
charger. That evening, the Tesla was parked and charging in the attached garage and while the
Sencaj family was watching television, they began to observe smoke and flames emanating from
the garage.
20. Investigation into the origin and cause of the Fire by STATE FARM, and experts
retained to investigate on its behalf, revealed the Fire originated at the Tesla and was caused by a
defective condition of the vehicle, which was present when the vehicle was placed into the stream
21. The Tesla battery is comprised of thousands of 18650 lithium-ion cells to produce
a 400 Volt DC High Voltage Battery (hereinafter “High Voltage Battery”). The vehicle design
placed the High Voltage Battery under the floor pan, and throughout the entire floor of the
passenger compartment.
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22. The 1300-pound high voltage battery is connected to the electrical system through
23. Due to a defect in design or manufacture, upon information and belief, the Tesla
vehicle’s electrical system failed, causing an electrical condition which ignited combustibles and
24. In connection with the Fire, pursuant to the terms and conditions of the insurance
policy, the Sencaj Family submitted claims to STATE FARM seeking indemnification and
reimbursement for fire damage to the Sencaj residence and its contents, as well as fire damage to
the vehicles.
25. In connection with the Fire, pursuant to the terms and conditions of the insurance
policy, STATE FARM was obligated to and did, in fact, pay approximately $1,271,702.26 to or
on behalf of the Sencaj Family for fire related damage to the Sencaj residence and its contents,
additional living expenses incurred by the Sencaj family, and fire damage to the vehicles.
26. Pursuant to the terms and conditions of the insurance policy and by virtue of its
payments to the Sencaj Family, STATE FARM is subrogated to all rights, claims and causes of
action the Sencaj Family may have against Defendant in connection with the Fire.
COUNT I
Negligence
28. At all times relevant, Defendant Tesla owed the Sencaj Family a duty to
exercise reasonable skill and care in designing, manufacturing, assembling, testing, inspecting,
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29. Notwithstanding this duty, and in breach thereof, Defendant Tesla, by and
through its employees, agents, and/or representatives, was negligent in one or more of the
following ways:
(a) The Tesla’s electrical system and/or its component parts were
defective in their design in that the Tesla’s electrical system did not
perform safely, but instead failed;
(b) The Tesla’s electrical system was defectively designed because the
risks of significant fire damage to consumers’ properties outweigh
any potential benefits derived from the Tesla’s electrical system
design;
(d) The Tesla’s electrical system and/or its component parts contained
manufacturing defects in that the Tesla’s electrical system differed
from the manufacturer’s design or specifications or from typical
units of the same product line;
(f) Tesla failed to instruct and inform consumers of the proper use of
the vehicle and dangers with the associated electrical system;
(g) The Tesla electrical system and/or its component parts were
designed, manufactured, and/or assembled without proper testing;
(h) The Tesla’s electrical system was defective in that it caught fire for
no apparent reason during its normal use;
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30. As a direct and proximate result of one or more of the foregoing negligent acts
and/or omissions on the part of Defendant Tesla, a significant electrical event occurred. The
electrical arcing event quickly ignited readily available combustibles within the Tesla, creating a
dangerous fire.
31. The fire damaged or destroyed the Tesla and spread to the Sencaj residence and
other vehicles where it caused significant damage to the Sencaj residence and its personal property
contents.
Randall W. and Dorothy S. Sencaj and STATE FARM MUTUAL AUTOMOBILE INSURANCE
COMPANY, as subrogee of Randall W. and Dorothy S. Sencaj request that judgement in the
amount of $1,271,702.26 be entered in their favor, and against Defendant Tesla and for such other
COUNT II
Strict Product Liability
33. Upon information and belief, the Tesla was defective and unreasonably dangerous
when it left Defendant Tesla's control and was placed into the stream of commerce.
34. Upon information and belief, after the Tesla was placed into the stream of
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35. At all relevant times, the Sencaj Family used the Tesla for its reasonably
36. When the Tesla left Defendant Tesla's control and was placed into the stream of
commerce, it was unreasonably dangerous and defective, in light of its foreseeable and intended
(a) The Tesla’s electrical system and/or its component parts were
defective in its design in that the Tesla’s electrical system did not
perform safely, but rather failed;
(b) The Tesla’s electrical system was defectively designed because the
risks of significant fire damage to consumers’ properties outweigh
any potential benefits derived from the Tesla vehicle’s design;
(d) The Tesla’s electrical system and/or its component parts contained
manufacturing defects in that the Tesla’s electrical system differed
from the manufacturer’s design or specifications or from typical
units of the same product line;
(e) The Tesla vehicle failed to contain adequate warnings for consumers
to be aware of possible hazards of the electrical system;
(g) The Tesla’s electrical system and/or its component parts were
designed, manufactured, and/or assembled without proper testing;
(h) The Tesla’s electrical system was defective in that it caught fire for
no apparent reason during its normal use;
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37. As a direct and proximate result of one or more of the foregoing defective and
unreasonably dangerous conditions of the Tesla, an electrical malfunction occurred within the
vehicle, causing an electrical arcing event. The electrical arcing event quickly ignited readily
available combustibles within the Tesla’s engine compartment, creating a dangerous fire.
38. The fire damaged or destroyed the Tesla, and spread to the Sencaj residence and
two other vehicles where it caused significant damage to the Sencaj residence and its personal
property contents.
Randall W. and Dorothy S. Sencaj and STATE FARM MUTUAL AUTOMOBILE INSURANCE
COMPANY, as subrogee of Randall W. and Dorothy S. Sencaj request that judgment in the
amount of $1,271,702.26 be entered in their favor, and against Defendant Tesla and for such other
Respectfully Submitted,