In subrogation cases where the insured’s damages were caused by a defective product, the fact that the product at issue is or was subject to a recall announced by the Consumer Product Safety Commission (CPSC) may help to establish that the product was defective when it left the manufacturer’s possession and control. On June 29, 2023, the CPSC announced the following recalls related to products that present fire hazards:

1. Victrola Recalls Bluetooth Record Players Due to Fire Hazard. According to the CPSC’s website, “[t]he recalled record players can overheat, posing a fire hazard.”
2. Bose Recalls Acoustimass®, Lifestyle® and Companion™ Bass Modules Due to Fire Hazard. According to the CPSC’s website, “[t]he speaker’s electrical components can fail, posing a fire hazard.”