Judge Frederic Block
Williams was severely burned while using an alcohol solvent made by Sunnyside Corp. Fumes, escaping from the sealed container through a punctured hole, ignited. Before using the solvent Williams read warning labels and understood the solvent was flammable. He committed suicide shortly after federal removal of his May 2008 personal injury suit. His wife Walker sought $20 million on claims centering on Sunnyside’s alleged failure to warn consumers of dangers and hazards associated with the solvent’s useparticularly the danger of flash fires. The court granted Sunnyside summary judgment on Walker’s claims. The Federal Hazardous Substances Act (FHSA) preempted Walker’s negligence and strict liability claims. The solvent’s front label clearly warned of the principal hazard of flash fires, in compliance with the FHSA. Further, the label provided more information than required by the FHSA regarding precautionary measures so as to avoid the risk of flash fires. Thus Sunnyside’s label complied with the "letter and spirit" of the FHSA and Consumer Product Safety Commission regulations. Also, Walker provided no evidence that the solvent’s label failed to satisfy FHSA requirements in 15 USC §1261(p)(2) and 16 CFR §1500.121.
