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 August 22, 2024 and August 29, 2024, the CPSC announced the following recalls related to products that present fire hazards:

1. HALO 1000 Portable Power Stations Recalled Due to Serious Fire and Burn Hazards; One Death Reported; Imported by ZAGG; Sold by ACG, QVC and ZAGG. According to the CPSC’s website, “[t]he lithium-ion batteries in the HALO 1000 Portable Power Station can overheat, posing fire and burn hazards that can lead to serious injury or death.”
2. Siemens Industry Recalls SolarReady™ Meter Combos Due to Fire Hazard. According to the CPSC’s website, “[a]n interior connection in the recalled Siemens SolarReady Meter Combos can overheat, posing a fire hazard.”