Doyle et al v. Combined Systems Inc et al

3:22-cv-01536TxndJan 6, 2026

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
VINCENT DOYLE, BRANDON
SAENZ, DAVID MCKEE, RANDI
ROGERS, and TASIA WILLIAMS,
Plaintiffs,
v.
COMBINED SYSTEMS, INC. and
PENN ARMS, INC.,
Defendants.
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Civil Action No. 3:22-CV-1536-K
MEMORANDUM OPINION AND ORDER
Before the Court are Defendants Combined Systems, Inc. and Penn Arms, Inc.’s
(together, the “Defendants”) Motion to Dismiss Plaintiffs’ Third Amended Petition for
Failure to State a Claim and Brief in Support (together, the “Motion”) (Doc. Nos. 49
& 50), Plaintiffs’ Response to Defendants’ Motion (the “Response”) (Doc. No. 51),
Defendants’ Reply in Support of the Motion and Brief in Support (together, the
“Reply”) (Doc. Nos. 52 & 53), and Plaintiffs’ Third Amended Complaint (the
“Amended Complaint”) (Doc. No. 47). The Court has carefully considered the Motion,
the Response, the Reply, and the Amended Complaint, as well as the applicable law
and the relevant portions of the record. The Court GRANTS the Motion.
I. 	Factual Background
The 	Court 	previously 	recited 	the 	relevant 	factual 	background 	in 	its
Memorandum Opinion and Order granting Defendants’ First Amended Motion to
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Dismiss for Plaintiffs’ Failure to State a Claim. See Doc. No. 40. However, the Court
will again address the relevant background leading to the present claims.
After the death of George Floyd, a black man killed by Minneapolis police
officers in May of 2020, protests occurred across the country. See Third Am. Compl. at
2–3, ¶11. These protests also occurred in Dallas, Texas beginning a few days after
George Floyd’s death and continuing through the summer months. Id. Plaintiffs
Vincent Doyle, Brandon Saenz, David McKee, Randi Rogers, and Tasia Williams each
took part in the Dallas-based protests at various points in time. See generally id. On May
30, 2020, Vincent Doyle went to downtown Dallas to photograph and film the
protests. Id. at 9, ¶21. Doyle stated that the protest was peaceful when police officers
ordered the crowds to disperse. Id. Doyle moved away to a parking lot, where he claims
a police officer shot him in the face with a “40mm single shot launcher compact” (the
“launcher(s)”) and rubber “kinetic impact projectiles” (the “rubber bullets”), which
were produced by Defendants. Id. at 9–10, ¶22; 1, ¶6. Doyle alleges that he sustained
significant damage to his left eye and underwent multiple surgeries. Id. at 11, ¶24.
Plaintiff Brandon Saenz was in the area of the Dallas-based protests on May,
30, 2020, the same day Doyle was shot with the rubber bullet. Id. at 11, ¶25. Saenz
was looking for his friend when he claims a police officer shot him in the eye with a
rubber bullet. Id. Saenz alleges that he lost his left eye and also sustained significant
injuries. Id. at 11–12, ¶25.
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Plaintiff Randi Rogers watched, but did not participate, in the Dallas-based
protests on May 30, 2020. Id. at 12, ¶26. Rogers complied with police orders to walk
in a certain direction, but Rogers briefly stopped to take a phone picture of police
officers wearing riot equipment. Id. at 13 , ¶26. Rogers alleges that a police officer then
shot her with a rubber bullet, which caused significant injuries. Id. at 13, ¶¶26–28.
Plaintiff David McKee was also present at the May 30, 2020 protests because
his friend requested that he go with her to downtown Dallas so she could photograph
the protests. Id. at 14, ¶29. As McKee walked with his friend, he encountered a wave
of people running from “smoke and gas,” and he went into the crowd to assist. Id. at
14, ¶¶29–30. Eventually, McKee encountered a group of police officers that were
carrying “shotguns and grenade launchers.” Id. at 15, ¶30. Once the police officers
ordered the crowds to disperse, McKee moved back while holding up a sign he had
found earlier. Id. at 15, ¶31. McKee claims that he was then shot by two rubber bullets
in both the bicep and groin. Id. at 15, ¶31. McKee alleges that he lost one of his testicles
due to the incident. Id. at 15, ¶32.
Plaintiff Tasia Williams protested on the Margaret Hunt Hill Bridge leading into
downtown Dallas on June 1, 2020. Id. at 16, ¶33. Police deployed smoke canisters and
tear gas at protesters on the bridge, which Williams retreated from. Id. at 17, ¶36.
Williams claims that she was then shot in the thigh by a rubber bullet, causing
significant injuries to her leg. Id. at 17–18, ¶¶36–37.
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All Plaintiffs allege that Defendants’ products, the rubber bullets and launchers
made of materials such as foam, plastic, rubber, wood, or “beanbag” material, are
excessively dangerous and cause severe injuries. See id. at 18–20, ¶¶38–42. Specifically,
Plaintiffs allege that these products “cannot be used safely” by police officers. Id. at 19,
¶39. Further, Plaintiffs cite to studies that they allege support the conclusion that
rubber bullets and other “kinetic impact projectiles” are excessively dangerous, cause
serious injury, and establish that “[kinetic impact projectiles] are not appropriate
weapons for use in crowd-control settings[.]” Id. at 20, ¶¶40–41.
II. 	Procedural History
A 	brief 	explanation 	of 	this 	case’s 	procedural 	history 	is 	important 	to
understanding the posture of the present Motion. On May 31, 2022, Vincent Doyle,
David McKee, and Brandon Saenz filed their Original Petition in Texas state court,
seeking 	damages 	caused 	by 	Defendants’ 	allegedly 	misleading 	marketing 	of 	the
launchers and the rubber bullets that the Dallas Police Department (“DPD”) purchased
and subsequently used against Plaintiffs. See generally Doc. No. 1 at 14–46 (“Exhibit
C”). That same day, Randi Rogers and Tasia Williams joined in an Amended Original
Petition. See id. at 49 (“Exhibit D”). On July 15, 2022, Defendants removed this case
to federal court, and on August 30, 2022, Plaintiffs filed their Second Amended
Complaint. See Doc. Nos. 1 & 14.
In their Second Amended Complaint, Plaintiffs alleged four causes of action:
“Strict Liability: Marketing Defect,” “Negligent and False Marketing” (i.e. negligent
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failure to warn), “Breach of Implied Warranty of Fitness for a Particular Purpose,” and
“Violations of the Texas Deceptive Trade Practices Act.” Doc. No. 14 at 21–27, ¶¶43–
63. In response to the Second Amended Complaint, Defendants filed their First
Amended Motion to Dismiss for Failure to State a Claim pursuant to Federal Rule of
Civil Procedure 12(b)(6) (the “First Amended Motion to Dismiss”). See Doc. No. 19.
The Court subsequently granted Defendants’ First Amended Motion to Dismiss. See
Doc. No. 40 (emphasis added).
In the Court’s previous Memorandum Opinion and Order (Doc. No. 40), the
Court dismissed without prejudice each of Plaintiffs’ claims asserted in their Second
Amended Complaint. See Doc. No. 40 at 35 (emphasis added). The Court found that
the 	Protection 	of 	Lawful 	Commerce 	in 	Arms 	Act 	(“PLCAA”) 	barred 	Plaintiffs’
marketing defect and negligent failure to warn claims. Id. at 13. The Court further
found that Plaintiffs’ warranty claim, at the time a breach of the implied warranty of
fitness for a particular purpose, was inadequately pled because “Plaintiffs [did] not
allege that the [DPD’s] use of Defendants’ products involved unusual crowd control
techniques.” Id. at 32. Rather, the Court found that the launchers and rubber bullets
were used for their ordinary purpose, namely crowd control. See id. Lastly, the Court
found that Plaintiffs inadequately pled their claim for violation of the Texas Deceptive
Trade Practices Act (“Texas DTPA”) because they failed to establish consumer status.
Id. at 33. Plaintiffs could not bring this claim as a “direct consumer” because they
“never directly sought nor acquired any goods or services” from Defendants. Id.
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Likewise, Plaintiffs could not bring this claim as “indirect consumers” because Plaintiffs
did not plausibly allege that the DPD purchased Defendants’ launchers and rubber
bullets “with the intention of benefitting Plaintiffs rather than furthering the DPD’s
own law enforcement purposes.” Id. at 34. However, the Court provided Plaintiffs time
to file a further amended complaint. Id. at 35.
On October 6, 2023, Plaintiffs filed their Motion for Leave to File Third
Amended 	Complaint 	(Doc. 	No. 	43), 	including 	their 	Proposed 	Third 	Amended
Complaint (Doc. No. 43-1). Thereafter, the Court issued an Order (Doc. No. 44)
requiring Plaintiffs to file supplemental briefing that “explain[s] why their proposed
amended strict liability marketing defect and negligent failure to warn allegations . . .
remedy the obstacles to the claims described in the Court’s [Memorandum Opinion
and Order] [].” Court’s Oct. 11, 2023 Order at 2. Specifically, in their Proposed Third
Amended Complaint, Plaintiffs did not propose any changes to their marketing defect
claim and only proposed a minimal and unresponsive change to their negligent failure
to warn claim. See id. at 1. Plaintiffs then filed their Supplemental Brief in Support of
Plaintiffs’ Motion for Leave to File Third Amended Complaint (Doc. No. 45).
In its Memorandum Opinion and Order issued on October 30, 2023 (Doc. No.
46), the Court dismissed Plaintiffs’ strict liability marketing defect and negligent failure
to warn claims with prejudice because “[n]one of [Plaintiffs’ proposed] changes [were]
responsive to the Court’s order of dismissal.” Doc. No. 46 at 1 (emphasis added). The
Court allowed Plaintiffs’ proposed amendments to their remaining claims. See id. at 7.
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Plaintiffs then filed their Third Amended Complaint (Doc. No. 47), the live pleading
in this case, asserting claims for breach of the implied warranty of merchantability and
violation of the Texas DTPA. Third Am. Compl. at 21–24, ¶¶43–54. Defendants
subsequently filed the present Motion, to which Plaintiffs filed their Response and
Defendants filed their Reply. Therefore, the Motion is now ripe for determination.
III. 	Legal Standard
In considering a motion to dismiss pursuant to Federal Rule of Civil Procedure
12(b)(6), the court must determine whether the plaintiff(s) has sufficiently stated a
claim upon which relief may be granted. F ED . R. CIV. P. 12(b)(6). The court must
presume all well-pleaded facts in the complaint to be true and resolve any ambiguities
or doubts regarding the sufficiency of the claims in plaintiff’s favor. Kane Enters. v.
MacGregor (USA), Inc., 322 F.3d 371, 374 (5th Cir. 2003); Campbell v. Wells Fargo Bank,
781 F.2d 440, 442 (5th Cir. 1986). However, “[t]hreadbare recitals of the elements of
a cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v.
Iqbal, 556 U.S. 662, 663 (2009); see Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555
(2007) (although the court must take as true all of the factual allegations in the
complaint, it is not “bound” to accept as true a legal conclusion couched as a factual
allegation.). In reviewing a Rule 12(b)(6) motion to dismiss, the court may only
consider “the complaint, any documents attached to the complaint, and any documents
attached to the motion to dismiss that are central to the claim and referenced by the
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complaint.” Lone Star Fund V (U.S.), L.P. v. Barclays Bank PLC, 594 F.3d 383, 387 (5th
Cir. 2010).
A plaintiff must plead “enough facts to state a claim to relief that is plausible on
its face.” Twombly, 550 U.S. at 570; see Kane Enters., 322 F.3d at 374 (plaintiff must
plead specific facts, not mere conclusory allegations, to avoid dismissal for failure to
state a claim). If a plaintiff pleads facts which allow the court to reasonably infer that
the defendant is liable for the alleged misconduct, the claim is facially plausible. See
Twombly, 550 U.S. at 570. While facial plausibility is not a “probability requirement,”
it mandates “more than a sheer possibility that a defendant has acted unlawfully.” Iqbal,
556 U.S. at 678; see Twombly, 550 U.S. at 556 (“[f]actual allegations must be enough
to raise a right to relief above the speculative level.”). In other words, the alleged facts
must nudge the plaintiff’s claims “across the line from conceivable to plausible.”
Twombly, 550 U.S. at 570. “[W]here the well-pleaded facts do not permit the court to
infer more than the mere possibility of misconduct, the complaint has alleged—but it
has not ‘show[n]’—‘that the pleader is entitled to relief.’” Iqbal, 556 U.S. at 679
(quoting F ED . R. CIV. P. 8(a)(2)).
IV. 	Application of the Law
Defendants Combined Systems, Inc. and Penn Arms, Inc. move the Court to
dismiss Plaintiffs’ claims. First, Defendants argue that Plaintiffs’ claim for violation of
the Texas DTPA must fail because Plaintiffs are not “consumers” as defined by the
Texas DTPA. Second, Defendants argue that Plaintiffs’ new breach of warranty claim
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must also fail because Plaintiffs have not stated a plausible claim for breach of the
implied warranty of merchantability.
A. 	Claim for Violation of the Texas DTPA
Plaintiffs claim that Defendants violated the Texas DTPA by selling launchers
and rubber bullets to the DPD because “that transaction was obviously intended to
benefit the general public upon which these weapons and ammunition were meant to
be employed,” thus making Plaintiffs “consumers” under the Texas DTPA. Third Am.
Compl. at 22, ¶46. To state an actionable claim under the Texas DTPA, a claimant
must classify as a “consumer.” See Brittan Commc’ns Int’l Corp. v. Sw. Bell Tel. Co., 313
F.3d 899, 907 (5th Cir. 2002) (“[t]o maintain a cause under the Texas DTPA, [the
plaintiff] must establish that (1) [plaintiff] is a consumer under the DTPA with respect
to its claim[.]”); see also Davis v. Wells Fargo Bank, N.A., 976 F. Supp. 2d 870, 886 (S.D.
Tex. Sept. 30, 2013) (“[c]onsumer status is a key element of any Texas [DTPA]
claim.”). To classify as a “consumer” under the Texas DTPA, a plaintiff must (1) “have
sought or acquired goods or services by purchase or lease” and (2) “the goods or services
purchased or leased must form the basis of the complaint.” Brittan, 313 F.3d at 907.
In their Response, Plaintiffs “acknowledge that this Court has already decided
against them on this claim.” Pls.’ Resp. at 3, n. 1. Plaintiffs’ statement is accurate. In
its previous Memorandum Opinion and Order dismissing Plaintiffs’ claims, the Court
found that “Plaintiffs cannot sue under the DTPA as direct consumers because
Plaintiffs never directly sought nor acquired any goods or services.” Doc. No. 40 at 33.
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The Court further determined that Plaintiffs did not qualify as “indirect” consumers
under the Texas DTPA because they had no involvement in the DPD’s purchase of
Defendants’ products and because they failed to plausibly allege that the DPD
purchased the launchers and rubber bullets for Plaintiffs’ benefit rather than for
“DPD’s own law enforcement purposes.” Id. at 34. In Plaintiffs’ Amended Complaint,
they now only claim that they were “third-party beneficiar[ies]” of the DPD’s purchase
of Defendants’ products because the transaction was “obviously intended to benefit
the general public[.]” Third Am. Compl. at 22, ¶46.
If a plaintiff did not directly seek or acquire goods or services by purchase or
lease, that plaintiff cannot establish its consumer status under the Texas DTPA unless
it is a third-party beneficiary of a transaction that is “specifically required by or
intended to benefit the [plaintiff] and the good was rendered to benefit the [plaintiff].”
Lukasik v. San Antonio Blue Haven Pools, 21 S.W.3d 394, 401 (Tex. App.—San Antonio
2000, no pet.) (collecting cases). To establish that it is more than a mere “incidental
beneficiary,” the plaintiff must show that the transaction was “consummated with an
intent to benefit the claimant.” Chamrad v. Volvo Cars of N. Am., 145 F.3d 671, 672 (5th
Cir. 1998) (emphasis added). If the plaintiff cannot prove that it is more than an
“incidental beneficiary” of the disputed transaction, the plaintiff cannot establish
consumer status. See Ewbank v. ChoicePoint, Inc., 551 F. Supp. 2d 563, 567 (N.D. Tex.
2008) (Kinkeade, J.) (granting summary judgment for defendant because the fact that
the plaintiff “may have benefitted, or been damaged, by the conduct of [the defendant]
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in providing [the] services [at issue] does not make [the plaintiff] a consumer under
the DTPA.” (emphasis added)).
Here, 	it 	is 	abundantly 	clear 	that 	Plaintiffs 	cannot 	establish 	“third-party
beneficiary” status. Plaintiffs state that Defendants’ sale of their products to the DPD
was “obviously” meant to benefit the public. Third Am. Compl. at 22, ¶46. Outside of
that 	singular 	conclusory 	assertion, 	Plaintiffs 	make 	no 	plausible 	allegations 	that
Defendants actually intended their products to benefit the crowds for which those
products may be utilized. See 	Chamrad, 145 	F.3d 	at 	672 (transaction must be
“consummated with an intent to benefit [the plaintiff].”). The Court finds it much more
likely that Defendants intended that their “less lethal” products benefit the DPD, a
law enforcement agency, for the purpose of controlling unruly crowds, a distinct law
enforcement action. Third Am. Compl. at 21, ¶43 (emphasis added); cf. Lara v. Lile, 828
S.W.2d 536, 542 (Tex. App.—Corpus Christi-Edinburg 1992, writ denied) (employer’s
acquisition of “safety-conscious” transportation services was not primarily intended to
benefit the plaintiff, and the positive safety element of those services was merely
“incidental.”). In any event, even if Plaintiffs were benefitted (or damaged) by a
transaction in which they had no involvement, that fact would only be enough to
establish their status as “incidental beneficiar[ies].” See Ewbank, 551 F. Supp. 2d at 567.
The Court finds that Plaintiffs fail to plausibly allege their claim for violation of
the Texas DTPA. Accordingly, the Court GRANTS the Motion as to this claim, and
the claim is DISMISSED WITH PREJUDICE.
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B. Claim for Breach of the Implied Warranty of Merchantability
Plaintiffs 	also 	assert 	a 	claim 	for 	breach 	of 	the 	implied 	warranty 	of
merchantability. 	Third 	Am. 	Compl. 	at 	21–22, 	¶¶43–45. 	Plaintiffs 	allege 	that
Defendants breached the warranty of merchantability because “these [launchers and
rubber bullets] lack a safe use for crowd control because they cause, even when used as
Defendants direct, severe and catastrophic injuries to the public[.]” Id. at 22, ¶44.
Plaintiffs further claim that Defendants promoted the launchers and rubber bullets as
“less lethal” alternatives to standard law enforcement weaponry. Id. at 21, ¶43.
To recover on a claim for breach of the implied warranty of merchantability in
Texas, a plaintiff must prove that “(1) the defendant sold or leased a product to the
plaintiff; (2) the product was unmerchantable; (3) the plaintiff notified the defendant of
the breach; and (4) the plaintiff suffered injury.” Polaris Indus., Inc. v. McDonald, 119
S.W.3d 331, 336 (Tex. App.—Tyler 2003, no pet.) (emphasis added). A product is
“unmerchantable” if it is “unfit for ordinary purposes.” Id. (emphasis added). To be
unfit for “ordinary” purposes, the product must have a defect that causes it to “lack []
something necessary for adequacy.” Id.; Plas-Tex, Inc. v. U.S. Steel Corp., 772 S.W.2d
442, 444 (Tex. 1989).
Plaintiffs’ breach of warranty claim relies solely on the premise that, because
Defendants’ products have the capability to cause significant injury when used for
crowd control purposes, those products are unfit for their ordinary purpose, namely
crowd control. See Third Am. Compl. at 22, ¶44. Further, Plaintiffs place significant
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emphasis on the fact that Defendants’ launchers and rubber bullets were advertised as
“less lethal” alternatives to standard law enforcement weaponry. See id. at 21, ¶43; 19,
¶39; 3, ¶12; see also Pls.’ Resp. at 9 (Plaintiffs argue that “[t]he intended purpose [of
Defendants’ products] is not to cause the crowd serious, or even any, injury.”).
Plaintiffs’ argument is wholly conclusory. Plaintiffs do not dispute that the
primary, intended purpose of Defendants’ launchers and rubber bullets is crowd
control. See id. at 21, ¶43. Rather, they allege that these products are unfit for their
ordinary purpose because they “lack a safe use for crowd control[.]” Id. at 22, ¶44.
However, the Court agrees with Defendants’ argument that “[t]he possibility of an
injury, albeit a ‘less lethal’ injury, is an inherent risk in using these products.” Defs.’
Reply at 8. Plaintiffs are not asserting a products liability claim. Rather, they are
asserting a breach of warranty claim. See Third Am. Compl. at 21, ¶43 (emphasis added).
“A product can be unreasonably dangerous while at the same time be fit for its intended
purposes. Deeds v. Whirlpool Corp., Civ. Action No. H-15-2208, 2016 WL 6070552, at
*5 (S.D. Tex. Oct. 17, 2016) (emphasis added); see also Mott v. Red’s Safe and Lock Servs.,
Inc., 249 S.W.3d 90, 98 (Tex. App.—Houston [1st Dist.] 2007, no pet.) (“whether a
product is unfit for its intended purpose is not an element of products liability and is a
significantly different question than whether a product is unreasonably dangerous.”
(emphasis added)). The Court makes no determination as to the reasonableness of the
alleged dangers associated with Defendants’ launchers and rubber bullets. However,
even assuming that Plaintiffs’ allegations of the products’ dangers are accurate, that
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alone 	does 	not 	establish 	that 	the 	products 	breach 	the 	implied 	warranty 	of
merchantability. Again, the Court agrees with Defendants that the possibility of injury
is inherent in Defendants’ products. See Defs.’ Reply at 8.
Plaintiffs fail to provide any further factual support for their allegation that
Defendants’ products are unmerchantable. See Iqbal, 556 U.S. at 663 (“[t]hreadbare
recitals of the elements of a cause of action, supported by mere conclusory statements,
do not suffice.”). Plaintiffs spend significant time discussing the dangers of Defendants’
products and the fact that these products are advertised as “less lethal” alternatives to
standard law enforcement weaponry. See Third Am. Compl. at 18–21, ¶¶38–42.
However, the Court will not spend similar amounts of time on that discussion. In the
end, Plaintiffs provide no plausible allegations as to how the potential for injury is
inconsistent with the “less lethal” description and makes the launchers and rubber
bullets unfit for their ordinary purpose.
Because Plaintiffs fail to plausibly allege breach of the implied warranty of
merchantability, the Court GRANTS the Motion as to this claim, and the claim is
likewise DISMISSED WITH PREJUDICE.
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V. 	Conclusion
For the foregoing reasons, the Court GRANTS Defendants Combined Systems,
Inc. and Penn Arms, Inc.’s Motion and DISMISSES WITH PREJUDICE each of
Plaintiffs’ claims against Defendants.
SO ORDERED.
Signed January 6th , 2026.
____________________________________
ED KINKEADE
UNITED STATES DISTRICT JUDGE
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