Samsung SDI Co. Ltd. has escaped a lawsuit over a vape battery explosion that severely injured a teenager, after the Seventh Circuit ruled Wednesday that the South Korean company never purposefully entered the retail vape battery market — a decision that underscores the razor-thin legal boundaries of product liability and jurisdiction.
In a 3–0 ruling, the court affirmed the dismissal of the suit brought by a minor known as B.D., who suffered third-degree burns and required skin grafts after a lithium-ion 18650 battery exploded in his pocket. The judges found that Samsung’s ties to Indiana weren’t close enough to justify the case being heard there.
The Burn, the Battery, and the Blowback
The injury occurred when B.D.’s stepfather bought a loose 18650 lithium-ion battery from a vape shop. The battery, manufactured by Samsung SDI, combusted spontaneously while in the boy’s pants pocket — a malfunction that landed him in the hospital for three weeks.
But the court wasn’t swayed by the tragedy alone. Despite the physical pain and financial damages, the key legal question was: Did Samsung SDI purposely make its way into the Indiana vape market where the battery was sold?
The panel said no, drawing a bright line between the company’s approved distribution network — which supplies batteries to be used inside battery packs for devices like laptops and power tools — and the aftermarket, loose-battery market where the explosive unit was sold.
