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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

DEBRA MCGOWAN, §

§ Civil Action No.: 3:22-CV-1765

Plaintiff, §

§ JURY DEMAND

v. §

§

SUNBEAM PRODUCTS, INC., §

§

Defendant. §

Plaintiff, DEBRA MCGOWAN (hereafter referred to as “Plaintiff”), by and through her 

undersigned counsel, JOHNSON BECKER, PLLC and CLARK VON PLONSKI 

ANDERSON hereby submits the following Complaint and Demand for Jury Trial against 

Defendant SUNBEAM PRODUCTS, INC. (hereafter referred to as “Defendant Sunbeam”), and 

alleges the following upon personal knowledge and belief, and investigation of counsel:

NATURE OF THE CASE

1. Defendant Sunbeam designs, manufactures, markets, imports, distributes and sells 

a wide-range of consumer products, including the subject “Crock-Pot Express Crock 

Multicooker,” which specifically includes the Model Number SCCPPC 600-V1 (referred to 

hereafter as “Pressure Cooker(s)”).

2. Defendant Sunbeam touts that its Pressure Cookers are designed with “safety in 

mind,”1 which include supposed “safety measures”2 such as “safety sensors”3 that purport to keep 

the lid from being opened while the unit is under pressure.

 1 See Sunbeam Products, Inc. Crock-Pot Express Crock Multicooker Owner’s Manual, pg. 10, 

attached hereto as Exhibit A

2 Id.

3 Id.

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3. Despite Defendant Sunbeam’s claims of “safety,” it designed, manufactured, 

marketed, imported, distributed and sold, both directly and through third-party retailers, a product 

that suffers from serious and dangerous defects. Said defects cause significant risk of bodily harm 

and injury to its consumers.

4. Specifically, said defects manifest themselves when, despite Defendant Sunbeam’s 

statements, the lid of the Pressure Cooker is removable with built-up pressure, heat and steam still 

inside the unit. When the lid is removed under such circumstances, the pressure trapped within 

the unit causes the scalding hot contents to be projected from the unit and into the surrounding 

area, including onto the unsuspecting consumers, their families and other bystanders. The Plaintiff 

in this case was able to remove the lid while the Pressure Cooker retained pressure, causing her 

serious and substantial bodily injuries and damages.

5. On November 24, 2020, the Consumer Products Safety Commission (“CPSC”) 

announced a recall of more than 900,000 of Defendant Sunbeam’s SCCPPC600-V1 pressure 

cookers, which includes the subject pressure cooker, after receiving “119 reports of lid 

detachment, resulting in 99 burn injuries ranging in severity from first-degree to thirddegree burns.”4

6. Defendant Sunbeam knew or should have known of these defects but has 

nevertheless put profit ahead of safety by continuing to sell its Pressure Cookers to consumers, 

failing to warn said consumers of the serious risks posed by the defects, and failing to timely recall 

the dangerously defective Pressure Cookers regardless of the risk of significant injuries to Plaintiff 

and consumers like her. 

 4 See the CPSC Recall notice from November 24, 2020 

(https://www.cpsc.gov/Recalls/2020/crock-pot-6-quart-express-crock-multi-cookers-recalled-bysunbeam-products-due-to-burn#), a copy of which is attached hereto as Exhibit B. 

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7. Defendant Sunbeam ignored and/or concealed its knowledge of these defects in its 

Pressure Cookers from the Plaintiff in this case, as well as the public in general, in order to continue 

generating a profit from the sale of said Pressure Cookers, demonstrating a callous, reckless, 

willful, depraved indifference to the health, safety and welfare of Plaintiff and consumers like her. 

8. As a direct and proximate result of Defendant Sunbeam’s conduct, the Plaintiff in 

this case incurred significant and painful bodily injuries, medical expenses, physical pain, mental 

anguish, and diminished enjoyment of life.

PLAINTIFF DEBRA MCGOWAN

9. Plaintiff is a resident and citizen of the city of Cedar Hill, County of Dallas, State 

of Texas.

10. On or about September 8 2020, Plaintiff suffered serious and substantial burn 

injuries as the direct and proximate result of the Pressure Cooker’s lid being able to be rotated and 

opened while the Pressure Cooker was still under pressure, during the normal, directed use of the 

Pressure Cooker, allowing its scalding hot contents to be forcefully ejected from the Pressure 

Cooker and onto Plaintiff. The incident occurred as a result of the failure of the Pressure Cooker’s 

supposed “Built-In Safety Features,” which purport to keep the consumer safe while using the 

Pressure Cooker. In addition, the incident occurred as the result of Defendant’s failure to redesign 

the Pressure Cooker, despite the existence of economical, safer alternative designs.

DEFENDANT SUNBEAM PRODUCTS, INC.

11. Defendant Sunbeam designs, manufacturers, markets, imports, distributes and sells 

a variety of consumer products5 including pressure cookers, toasters, panini makers, and mixers, 

amongst others. 

 5 See generally, https://www.sunbeam.com/ (last accessed July 22, 2022).

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12. Defendant Sunbeam claims that through its “cutting-edge innovation and intelligent 

design”6 it has been “simplifying the lives of everyday people”7 for “over 100 years”.8

13. Defendant Sunbeam is a Delaware Corporation with its registered place of business 

at 1293 North University Drive, #322 City of Coral Springs, Broward County, Florida 33071, and 

its principal place of business located at 2381 Executive Center Drive, Boca Raton, Florida 33431.

JURISDICTION AND VENUE

14. This Court has subject matter jurisdiction over this case pursuant to diversity 

jurisdiction prescribed by 28 U.S.C. § 1332 because the matter in controversy exceeds the sum or 

value of $75,000, exclusive of interest and costs, and there is complete diversity between the 

parties.

15. Venue is proper in this Court pursuant to 28 U.S.C. § 1391 because all or a 

substantial part of the events or omissions giving rise to this claim occurred in this district.

16. Venue is also proper in this Court pursuant to 28 U.S.C. § 1391 because Defendant 

has sufficient minimum contacts with the State of Texas and has intentionally availed itself of the 

markets within Texas through the promotion, sale, marketing, and distribution of its products.

FACTUAL BACKGROUND

17. Defendant Sunbeam is engaged in the business of designing, manufacturing, 

warranting, marketing, importing, distributing and selling the Pressure Cookers at issue in this 

litigation.

 6 See, https://www.newellbrands.com/our-brands/sunbeam (last accessed July 22, 2022).

7 Id. 

8 Id.

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18. Defendant Sunbeam aggressively warrants, markets, advertises and sells its 

Pressure Cookers as “an all-in-one appliance that’s always ready when you are,”9 allowing 

consumers to cook “instant, healthy, home-cooked dish in under an hour.”10

19. According to the Owner’s Manual11 accompanying each individual unit sold, the 

Pressure Cookers purport to be designed with “safety in mind and has various safety measures.”12

20. For instances, the Defendant Sunbeam claims that it’s pressure cookers include 

“safety sensors”13 to keep the lid from being opened while the unit is under pressure; that 

“[p]ressure will not build if the Lid is not shut correctly and has not sealed”14; and that “[o]nce the 

pressure increases, the Lid cannot be opened.”15

21. In addition to the “safety measures” listed in the manual, Defendant Sunbeam’s 

Crock-Pot website claims that consumers can “cook with confidence” because the “airtight locking 

lid remains locked while pressure is inside the unit.”16

22. On November 24, 2020, the Consumer Products Safety Commission (“CPSC”) 

announced a recall of more than 900,000 of Defendant Sunbeam’s SCCPPC600-V1 pressure 

cookers, which includes the subject pressure cooker, after receiving “119 reports of lid 

detachment, resulting in 99 burn injuries ranging in severity from first-degree to thirddegree burns.”17

 9 See https://www.crock-pot.com/multi-cookers/express-crock/crock-pot-6-quart-express-crockmulti-cooker/SCCPPC600-V1.html (last accessed July 22, 2022).

10 Id. 

11See Sunbeam Products, Inc. Crock-Pot Express Crock Multicooker Owner’s Manual (“Exhibit 

A”), pg. 10. 12 Id.

13 Id.

14 Id.

15 Id.

16 See https://www.crock-pot.com/multi-cookers/express-crock/crock-pot-6-quart-express-crockmulti-cooker/SCCPPC600-V1.html (last accessed July 22, 2022). 17 See the CPSC Recall notice from November 24, 2020 

(https://www.cpsc.gov/Recalls/2020/crock-pot-6-quart-express-crock-multi-cookers-recalled-byCase 3:22-cv-01765-E Document 1 Filed 08/12/22 Page 5 of 12 PageID 5
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23. By reason of the forgoing acts or omissions, the above-named Plaintiff and/or her 

family purchased their Pressure Cooker with the reasonable expectation that it was properly 

designed and manufactured, free from defects of any kind, and that it was safe for its intended, 

foreseeable use of cooking. 

24. Plaintiff used her Pressure Cooker for its intended purpose of preparing meals for 

herself and/or family and did so in a manner that was reasonable and foreseeable by Defendant 

Sunbeam.

25. However, the aforementioned Pressure Cooker was defectively designed and 

manufactured by Defendant Sunbeam in that it failed to properly function as to prevent the lid 

from being removed with normal force while the unit remained pressurized, despite the appearance 

that all the pressure had been released, during the ordinary, foreseeable and proper use of cooking 

food with the product; placing the Plaintiff, her family, and similar consumers in danger while 

using the Pressure Cookers. 

26. Defendant Sunbeam’s Pressure Cookers possess defects that make them 

unreasonably dangerous for their intended use by consumers because the lid can be rotated and 

opened while the unit remains pressurized.

27. Further, Defendant Sunbeam’s representations about “safety” are not just 

misleading, they are flatly wrong, and put innocent consumers like Plaintiff directly in harm’s way.

28. Economic, safer alternative designs were available that could have prevented the 

Pressure Cooker’s lid from being rotated and opened while pressurized. 

29. As a direct and proximate result of Defendant Sunbeam’s intentional concealment 

of such defects, its failure to warn consumers of such defects, its negligent misrepresentations, its 

failure to remove a product with such defects from the stream of commerce, and its negligent 

 

sunbeam-products-due-to-burn#), a copy of which is attached hereto as Exhibit B. 

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design of such products, Plaintiff used an unreasonably dangerous Pressure Cooker, which resulted 

in significant and painful bodily injuries upon Plaintiff’s simple removal of the lid of the Pressure 

Cooker. 

30. Consequently, the Plaintiff in this case seeks damages resulting from the use of 

Defendant Sunbeam’s Pressure Cooker as described above, which has caused the Plaintiff to suffer 

from serious bodily injuries, medical expenses, physical pain, mental anguish, diminished 

enjoyment of life, and other damages.

CLAIMS FOR RELIEF

COUNT I

STRICT LIABILITY

31. Plaintiff incorporates by reference each preceding and succeeding paragraph as 

though set forth fully at length herein.

32. At the time of Plaintiff’s injuries, Defendant Sunbeam’ pressure cookers were 

defective and unreasonably dangerous for use by foreseeable consumers, including Plaintiff.

33. Defendant Sunbeam’ pressure cookers were in the same or substantially similar 

condition as when they left the possession of Defendant Sunbeam.

34. Plaintiff did not misuse or materially alter the pressure cooker.

35. The pressure cookers did not perform as safely as an ordinary consumer would have 

expected them to perform when used in a reasonably foreseeable way.

36. Further, a reasonable person would conclude that the possibility and serious of harm 

outweighs the burden or cost of making the pressure cookers safe. Specifically: 

a. The pressure cookers designed, manufactured, sold, and supplied by Defendant 

Sunbeam were defectively designed and placed into the stream of commerce in a 

defective and unreasonably dangerous condition for consumers;

b. The seriousness of the potential burn injuries resulting from the product drastically 

outweighs any benefit that could be derived from its normal, intended use;

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c. Defendant Sunbeam failed to properly market, design, manufacture, distribute, 

supply, and sell the pressure cookers, despite having extensive knowledge that the 

aforementioned injuries could and did occur;

d. Defendant Sunbeam failed to warn and place adequate warnings and instructions 

on the pressure cookers;

e. Defendant Sunbeam failed to adequately test the pressure cookers; and

f. Defendant Sunbeam failed to market an economically feasible alternative design, 

despite the existence of economical, safer alternatives, that could have prevented 

the Plaintiff’ injuries and damages.

37. Defendant Sunbeam actions and omissions were the direct and proximate cause of 

the Plaintiff’s injuries and damages.

WHEREFORE, Plaintiff demands judgment against Defendant Sunbeam for damages, 

together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court deems 

proper.

COUNT II

NEGLIGENCE

38. Plaintiff incorporates by reference each preceding and succeeding paragraph as 

though set forth fully at length herein.

39. Defendant Sunbeam had a duty of reasonable care to design, manufacture, market, 

and sell non-defective pressure cookers that are reasonably safe for their intended uses by 

consumers, such as Plaintiff and her family.

40. Defendant Sunbeam failed to exercise ordinary care in the manufacture, sale, 

warnings, quality assurance, quality control, distribution, advertising, promotion, sale and 

marketing of its pressure cookers in that Defendant Sunbeam knew or should have known that said 

pressure cookers created a high risk of unreasonable harm to the Plaintiff and consumers alike.

41. Defendant Sunbeam was negligent in the design, manufacture, advertising, 

warning, marketing and sale of its pressure cookers in that, among other things, it:

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a. Failed to use due care in designing and manufacturing the pressure cookers to avoid 

the aforementioned risks to individuals; 

b. Placed an unsafe product into the stream of commerce; 

c. Aggressively over-promoted and marketed its pressure cookers through television, 

social media, and other advertising outlets; and 

d. Were otherwise careless or negligent.

WHEREFORE, Plaintiff demands judgment against Defendant Sunbeam for damages, 

together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court deems 

proper.

COUNT III

BREACH OF IMPLIED WARRANTY OF FITNESS

FOR A PARTICULAR PURPOSE

42. Plaintiff incorporates by reference each preceding and succeeding paragraph as 

though set forth fully at length herein.

43. Defendant Sunbeam manufactured, supplied, and sold their pressure cookers with 

an implied warranty that they were fit for the particular purpose of cooking quickly, efficiently 

and safely. 

44. Members of the consuming public, including consumers such as the Plaintiff, were 

the intended third-party beneficiaries of the warranty.

45. Defendant Sunbeam’ pressure cookers were not fit for the particular purpose as a 

safe means of cooking, due to the unreasonable risks of bodily injury associated with their use as 

described herein in this Complaint. 

46. The Plaintiff in this case reasonably relied on Defendant Sunbeam’ representations 

that its pressure cookers were a quick, effective and safe means of cooking.

47. Defendant Sunbeam’ breach of the implied warranty of fitness for a particular 

purpose was the direct and proximate cause of Plaintiff’s injuries and damages.

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WHEREFORE, Plaintiff demands judgment against Defendant Sunbeam for damages, 

together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court deems 

proper.

COUNT IV

BREACH OF IMPLIED WARRANTY OF MERCHANTABILITY

48. Plaintiff incorporates by reference each preceding and succeeding paragraph as 

though set forth fully at length herein.

49. At the time Defendant Sunbeam marketed, distributed and sold their pressure 

cookers to the Plaintiff in this case, Defendant Sunbeam warranted that its Pressure cookers were 

merchantable and fit for the ordinary purposes for which they were intended.

50. Members of the consuming public, including consumers such as the Plaintiff, were 

intended third-party beneficiaries of the warranty.

51. Defendant Sunbeam’ pressure cookers were not merchantable and fit for their 

ordinary purpose, because they had the propensity to lead to the serious personal injuries as 

described herein in this Complaint. 

52. The Plaintiff in this case and/or her family purchased and used the pressure Cooker 

with the reasonable expectation that it was properly designed and manufactured, free from defects 

of any kind, and that it was safe for its intended, foreseeable use of cooking.

53. Defendant Sunbeam’ breach of implied warranty of merchantability was the direct 

and proximate cause of Plaintiff’s injury and damages.

WHEREFORE, Plaintiff demands judgment against Defendant Sunbeam for damages, 

together with interest, costs of suit, attorneys’ fees, and all such other relief as the Court deems 

proper.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiff demands judgment against the Defendant Sunbeam for 

damages, including exemplary damages if applicable, to which she is entitled by law, as well as 

all costs of this action, interest and attorneys’ fees, to the full extent of the law, whether arising 

under the common law and/or statutory law, including:

a. judgment for Plaintiff and against Defendant Sunbeam;

b. damages to compensate Plaintiff for her injuries, economic losses and pain and 

suffering sustained as a result of the use of the Defendant Sunbeam’ pressure 

cookers;

c. pre and post judgment interest at the lawful rate;

d. punitive damages on all applicable Counts as permitted by the law;

e. a trial by jury on all issues of the case;

f. an award of attorneys’ fees; and

g. for any other relief as this Court may deem equitable and just, or that may be 

available under the law of another forum to the extent the law of another forum is 

applied, including but not limited to all reliefs prayed for in this Complaint and in 

the foregoing Prayer for Relief.

DATED this 12th day of August 2022.

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Respectfully submitted,

CLARK │VON PLONSKI │ANDERSON

By: /s/ Collen A. Clark

COLLEN A. CLARK

State Bar No. 04309100

3500 Maple Avenue, Suite 1250

Dallas, Texas 75219

214-780-0500/214-780-0501 Fax

eservice@cvpalaw.com

In association with:

JOHNSON BECKER, PLLC

Adam J. Kress, Esq. (#0397289)

Pro Hac Vice to be filed

444 Cedar Street, Suite 1800

(612) 436-1800 / (612) 436-1801 (fax)

akress@johnsonbecker.com

Attorneys for Plaintiff

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