On June 16, 2025, the United States District Court for the Eastern District of Pennsylvania granted the defendant’s Motion to Dismiss under Rule 12(b)(6) in Williams v. W.M. Barr & Co., 2025 U.S. Dist. Lexis 114387, 2025 WL 1689388 (E.D. Pa. June 16, 2025). In a published memorandum, the Court methodically dismissed each of the plaintiffs’ claims against defendant, W.M. Barr (“Barr”), based on consideration of the “undisputably authentic” labeling on the product packaging.
The matter concerned the spontaneous combustion of rags saturated with Klean-Strip Boiled Linseed Oil (“Linseed Oil”), after plaintiff, Kenneth Williams, placed rags soaked in the Linseed Oil in a bucket with other cleaning rags, which caused substantial fire damage to the plaintiffs’ property. The plaintiffs, Kenneth and Lydia Williams, filed suit in the Eastern District of Pennsylvania, alleging that the Linseed Oil was defective in design and warnings, the Linseed Oil breached the implied warranty of merchantability, and the Defendant was negligent in its manufacturing, design, and warning of the product.
In Barr’s Motion to Dismiss, it included photographs of the front and rear panels of the Linseed Oil packaging: the front contained a warning stating “CAUTION! CAN CAUSE SPONTANEOUS COMBUSTION” and the back contained a warning stating “RISK OF FIRE FROM SPONTANEOUS COMBUSTION EXISTS WITH THIS PRODUCT,” an explanation of why and how Linseed can spontaneously combust, and instructions on how to handle oily materials after use.
The Barr Court explained that in most cases, the trial court is only allowed to consider the pleadings when considering a motion to dismiss. In re Burlington Coat Factory Sec. Litig., 114 F.3d 1410, 1426 (3d Cir. 1997). However, a court may consider documents integral to or explicitly relied upon in the plaintiff’s complaint and/or any undisputedly authentic document of which the plaintiff’s claims are based upon. Pension Benefit Guar. Corp. v. White Consol. Indus., Inc., 998 F.2d 1192, 1196 (3d Cir. 1993). An undisputedly authentic document is one that “no party questions.” First Nonprofit Ins. Co. v. Meenan Oil LLC, 462 F. Supp. 3d 537, 542 (E.D. Pa. 2020).
Here, the Linseed Oil packaging satisfied both requirements, although only one was necessary, to be considered with Defendant’s motion to dismiss. Since the plaintiffs alleged that the Linseed Oil container failed to adequately warn of its susceptibility to self-heating and spontaneous combustion, the plaintiffs explicitly relied upon the Linseed Oil packaging in their failure-to-warn claim. Furthermore, due to allegations that Barr labeled the Linseed Oil, the plaintiffs’ own production of the depicted packaging at a site inspection, and the plaintiffs’ concession that the product contained warnings, the Court accepted the photographs of the packaging, which the plaintiffs’ claims were based on, as “undisputedly authentic.”
Upon examination of the warning label, the Court noted that the container explicitly warned of the exact danger that occurred, and the label provided explicit instructions on how to avoid the exact outcome that plaintiffs experienced. Referring to the warning labels and instructions on how to handle oily materials printed on the Linseed Oil packaging, the Court determined that the plaintiffs’ negligent or defective failure to warn claims were implausible, and the Court dismissed those claims, without prejudice. The court also concluded that the plaintiffs’ design, manufacture, and implied warranty of merchantability claims consisted of mere legal conclusions insufficient to survive a motion to dismiss and dismissed those claims, without prejudice, as well. Accordingly, with no claims remaining, the Complaint was dismissed, without prejudice, and with leave to amend.
Under standard circumstances, a court generally must rely only on the pleadings when considering a motion to dismiss, but the Barr court was able to consider the product packaging, which aided in their dismissal of the plaintiffs’ Complaint. This was due to the packaging being explicitly relied upon in the Complaint and, separately, being an “undisputably authentic” document of which the plaintiffs’ warning defect strict liability and negligent failure to warn claims were based upon.
The Barr Memorandum can be found here.
For additional questions, please contact Conrad James Benedetto, Esq. and/or Steven E. Tambon, Esq.
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