Axline v. 3M Company, No. 19-1180 (8th Cir. 2021)Annotate this Case
Plaintiff, whose case is part of the Bair Hugger multidistrict litigation (MDL) against 3M, appeals the district court's orders deciding that Ohio substantive law applies in her case and denying her motion for leave to amend her complaint. The Eighth Circuit affirmed, concluding that, after consideration of the eleven factors that may be considered in an Ohio choice-of-law analysis, the district court did not err in deciding that Ohio substantive law governed this case. In this case, plaintiff has not rebutted the presumption that the substantive law of Ohio, the state where she was injured, governs this products liability case. The court also concluded that the district court did not abuse its discretion in denying plaintiff's motion for leave to amend the complaint where plaintiff failed to comply with local rules.