Riley v. Champion International Corp.
This case involves a lawsuit brought by Charles and Helen Riley against Champion International Corporation. Charles Riley, an independent logging contractor, contracted Lyme disease from a tick bite on Champion's property. Plaintiffs alleged negligence, gross negligence, negligent misrepresentation, and breach of contract for Champion's failure to warn about Lyme disease, and Helen Riley claimed loss of consortium and household services. The Magistrate Judge recommended granting summary judgment on most tort claims but denying it for breach of contract. The Chief Judge adopted parts of this, affirming summary judgment on premises liability and misrepresentation negligence claims. However, the Chief Judge overruled the Magistrate Judge's conclusion on the "increased risk of harm" prong of Restatement (Second) of Torts § 323, finding a genuine issue of material fact as to whether Champion's failure to provide safety information increased the risk of developing a chronic Lyme infection. Consequently, claims for breach of contract, negligent performance, gross negligence, loss of consortium, loss of household services, and punitive damages were revived for trial.