By Timothy S. Donahue

Top Takeaways:

• The Seventh Circuit Court ruled that Samsung SDI is not liable for a vape battery explosion in Indiana, citing lack of jurisdiction.
• The court emphasized that Samsung SDI does not market or sell its batteries for standalone consumer use, including in vaping products.
• The decision could have wide-reaching implications for the nicotine industry, especially for retailers who sell high-capacity lithium-ion batteries individually.

Samsung SDI has been cleared of responsibility in a lawsuit over a vape battery explosion that injured a teenager in Indiana. In a unanimous decision, the Seventh Circuit Court of Appeals ruled that the battery manufacturer could not be held liable because it had no direct connection to the state’s vape market and did not intend its batteries to be sold for individual use in vaping devices.

The lawsuit stemmed from a 2020 incident in which a 13-year-old boy, identified as B.D., suffered third-degree burns after a lithium-ion 18650 battery exploded in his pocket. The battery had been purchased by his stepfather at a local vape shop. The boy required extensive medical treatment, including skin grafts.

B.D. and his family filed suit against Samsung SDI, a South Korean company that produces batteries used in devices like laptops and power tools. The claim alleged that the battery was defectively designed and that Samsung should be liable for the injuries. However, Samsung argued that it never sold the battery for individual consumer use—especially not for vaping—and had taken steps to prevent its products from being used in that way.

The Seventh Circuit agreed. Writing for the three-judge panel, Judge Michael Brennan noted that Samsung SDI sells batteries to sophisticated manufacturers who assemble them into battery packs for specific devices. The company includes contractual language prohibiting the sale of loose cells to the general public and does not market or distribute the batteries for vaping purposes.

“Samsung structured its business to prevent ordinary consumers from purchasing these individual batteries in Indiana,” Judge Brennan wrote in the court’s opinion. “The unilateral actions of third parties made individual 18650 batteries accessible to Indiana consumers. Samsung SDI had no hand in directing individual 18650 batteries to Indiana.”

The court emphasized the distinction between “end-product” markets—where batteries are sold as part of finished devices like laptops—and “derivative-product” markets, such as the sale of individual battery cells for purposes like vaping. Because Samsung operated only in the end-product space and took active measures to avoid sales into the consumer market, the court found no grounds for personal jurisdiction.

The case had originally been dismissed by a district court in Indiana, but the plaintiffs appealed, arguing that Samsung should still be held liable because its batteries ended up in the state. The appellate court disagreed, saying the mere presence of a product in a market is not sufficient to establish jurisdiction unless the manufacturer intended it to be there.

Legal observers say the ruling could have significant implications for the nicotine and vaping industries, particularly in cases involving battery-related injuries. While manufacturers may avoid liability by limiting their distribution channels and including proper warnings, retailers and distributors who sell loose lithium-ion batteries could now face greater legal exposure.

Battery explosions linked to vaping devices have been a persistent concern in recent years, as high-capacity lithium-ion cells are often used improperly or without adequate casing. The U.S. Food and Drug Administration has issued multiple warnings about battery safety and the dangers of using unregulated components in e-cigarettes and vaping products.

The plaintiff’s legal team argued that Samsung should have known its batteries were being sold for unauthorized purposes and should have done more to prevent such uses. However, the court found no evidence that Samsung targeted the Indiana market or had any relationship with the retailer that sold the battery.

Samsung’s victory aligns with similar decisions in other federal appellate courts, including the Ninth Circuit, but contrasts with rulings in the Fifth Circuit, where courts have been more willing to find jurisdiction in product liability cases involving third-party sales.

The case underscores the importance of clear supply chain controls for component manufacturers, particularly those whose products are used in high-risk consumer applications like vaping. For the nicotine industry, it highlights a gap in responsibility between manufacturers of core components and the retailers who sell them to end users.

While Samsung SDI is now shielded from liability in this case, the ruling leaves unresolved the broader issue of how to regulate the aftermarket sale of high-capacity batteries. Vape shops and online retailers that sell 18650 cells without safety mechanisms could still be held accountable in future lawsuits.

The FDA has not mandated any specific battery standards for vaping devices, but several states have considered regulations aimed at curbing the sale of loose lithium-ion cells.

The plaintiff’s legal team has not yet announced whether it will appeal the Seventh Circuit’s decision to the U.S. Supreme Court. For now, the ruling is a clear win for Samsung SDI and a potential benchmark for other battery makers defending against similar lawsuits.