Amazon E-Bike Negligence Lawsuits: Seller Liability by State

If a defective e-bike bought on Amazon injures you, whether you can win an Amazon e-bike lawsuit depends largely on the state where you file. California courts have held Amazon strictly liable for defective third-party products sold through Fulfilled by Amazon; New York courts have called Amazon a mere platform and dismissed the same kind of claim. A separate theory — that Amazon voluntarily took on a safety duty and then failed to carry it out — is gaining traction in courts that reject strict liability. And in 2024, the federal Consumer Product Safety Commission ruled that Amazon is a “distributor” responsible for hazardous goods sold through its warehouses, a finding Amazon is now fighting in federal court.

Recent E-Bike Injury Suits Against Amazon

Two recent cases illustrate what these lawsuits look like.

On December 30, 2024, California resident Robert Lewis was riding a foldable e-bike made by US Actbest Technology Inc. and sold on Amazon for around $369. The bike’s handlebar locking mechanism failed without warning, the handlebars collapsed, and Lewis was thrown from the bike. He fell into a coma and sustained a spinal cord injury that left him permanently paralyzed from the waist down.1AboutLawsuits.com. Amazon E-Bike Lawsuit Defective Foldable Design Paralyzation

Lewis and his family sued Amazon.com, Inc. and Actbest in Los Angeles Superior Court on June 16, 2025. Beyond standard strict liability and negligence counts, the complaint adds a “negligent undertaking” claim aimed only at Amazon, alleging the company promised consumers it would monitor complaints and remove unsafe items but ignored prior complaints about this same defect. The family seeks general, economic, non-economic, and punitive damages.1AboutLawsuits.com. Amazon E-Bike Lawsuit Defective Foldable Design Paralyzation2Electrek. California Man Sues Amazon After Catastrophic Electric Bike Crash

A second case, filed April 7, 2026, in the U.S. District Court for the District of Oregon, involves Garry Cunanan. He alleges the front wheel of his Ridstar Q20 e-bike detached at roughly 20 miles per hour, sending him face-first to the ground and causing permanent facial fractures, jaw and dental deformity, and disfigurement. Amazon.com Services LLC is the only named defendant. Cunanan claims strict liability, negligence, and recklessness, alleging Amazon knew of prior complaints about the same defect but kept selling the bike.3AboutLawsuits.com. Lawsuit Amazon Electric Bike Malfunction Facial Dental Injuries

The Ridstar Q20 has drawn separate federal attention. On March 19, 2026, the CPSC urged consumers to immediately stop using the Ridstar Q20 and Q20 Pro after 11 fires, one burn injury, five smoke inhalation cases, and more than $40,000 in property damage. The Chinese manufacturer refused to recall the bikes.4CPSC. CPSC Warns Consumers to Immediately Stop Using Ridstar E-Bikes Due to Fire Hazard

Is Amazon a “Seller” You Can Sue?

Every product liability case against Amazon runs into the same threshold question: is Amazon legally a seller or distributor of the product, or just a platform connecting buyers to third-party vendors? Product liability law generally reaches sellers in the chain of commerce. If Amazon is not a seller, most of these claims fail before they reach the merits.

Courts have split.

California Says Yes

In Bolger v. Amazon.com, LLC (2020), the California Court of Appeal held that Amazon is an “integral link in the chain of distribution” for products sold through Fulfilled by Amazon and can be held strictly liable when those products are defective. The case involved a laptop battery, but the reasoning applies broadly.5FindLaw. Bolger v. Amazon.com, LLC

The court focused on what Amazon actually does: it stores the product in its warehouses, provides the listing, processes payment, ships in Amazon-branded packaging, controls the customer relationship, restricts the seller’s access to customer data, and charges fees. Those activities, the court said, make Amazon pivotal to the sale, not a passive intermediary. The court also observed that Amazon is often the only defendant an injured buyer can practically reach when the third-party seller is overseas or judgment-proof.5FindLaw. Bolger v. Amazon.com, LLC

Wisconsin courts have reached similar conclusions.6Proskauer. Recent Rulings Highlight Limits of CDA Immunity in Products Liability Cases Against E-Commerce Platforms

New York Says No

In Wallace v. Tri-State Assembly, LLC (2021), New York’s Appellate Division dismissed negligence and warranty claims against Amazon brought by a plaintiff whose e-bike handlebars loosened after purchase. The bike was listed by a China-based seller and assembled by a New York company. Amazon was the only defendant within reach.7Studicata. Wallace v. Tri-State Assembly, LLC

The court held Amazon did not sell, manufacture, distribute, or assemble the bike. Because the seller shipped directly and Amazon never took possession or title, the court classified Amazon as a “provider of services” and a “marketing platform” outside the chain of commerce. It also found that Amazon’s Conditions of Use disclaimed warranties for third-party products. The plaintiff was left with no remedy, and the court declined to create one.7Studicata. Wallace v. Tri-State Assembly, LLC

Pennsylvania and Tennessee: Unresolved or Mixed

The Third Circuit in Oberdorf v. Amazon (2019) initially held Amazon could be strictly liable under Pennsylvania law for a defective retractable dog leash that blinded a woman. The court then granted rehearing en banc, vacated the opinion, and certified the question to the Pennsylvania Supreme Court. The case settled in September 2020 before the state court could answer, leaving Pennsylvania law unsettled.8Villanova Law Review. Oberdorf v. Amazon Settles Leaving Question of Amazon’s Strict Liability Under PA Law Unanswered

The Sixth Circuit, applying Tennessee law in Fox v. Amazon, ruled Amazon was not a “seller” of a defective hoverboard but allowed negligence claims to proceed on the theory that Amazon had voluntarily assumed a safety duty by sending warnings to purchasers.6Proskauer. Recent Rulings Highlight Limits of CDA Immunity in Products Liability Cases Against E-Commerce Platforms

The result is a patchwork. Whether you can hold Amazon strictly liable depends on which state’s law governs your case.

The Negligent Undertaking Workaround

Even where courts refuse to call Amazon a seller, plaintiffs have found another route: negligent undertaking. The argument is that Amazon publicly promised to police its marketplace for unsafe products through safety review programs, complaint monitoring, and automated screening, and having taken on that duty, it must carry it out with reasonable care.

A federal court in Texas endorsed this theory in Johnson v. Amazon.com, Inc. (No. 4:22-CV-04086), a case involving a defective bathmat sold by a Chinese third-party seller. The court let the negligence claim proceed, pointing to Amazon’s public announcement of a $400 million investment in product safety and compliance, its customer service pages describing safety investigation procedures, and its automated tools for scanning listings. Those commitments, the court found, moved Amazon past the role of a “mere marketplace” into one that had assumed and then breached a duty.6Proskauer. Recent Rulings Highlight Limits of CDA Immunity in Products Liability Cases Against E-Commerce Platforms

The Lewis complaint leans on the same theory, alleging Amazon “voluntarily assumed and promised consumers” it would monitor product complaints and remove unsafe items, then “negligently carries out this service by ignoring obvious design, manufacturing and warning defects.”2Electrek. California Man Sues Amazon After Catastrophic Electric Bike Crash Because that case is in California, the plaintiffs can pursue strict liability under Bolger at the same time.

A Consumer Reports investigation adds evidence for the negligent-undertaking argument. Amazon requires sellers to provide paperwork showing certification to the UL 2849 safety standard for e-bikes, but a spot check of top-selling e-bikes priced under $800 found that none appeared in the UL certification database.9Consumer Reports. Electric Bike Fires and Lithium-Ion Batteries The gap between Amazon’s stated policy and what actually appears on its marketplace is what these claims target.

The CPSC Called Amazon a Distributor

On July 30, 2024, the Consumer Product Safety Commission unanimously ruled that Amazon meets the federal definition of a “distributor” under the Consumer Product Safety Act for products sold through Fulfilled by Amazon. An administrative law judge found that FBA gives Amazon “far-reaching control” over products in its warehouses, and the Commission rejected Amazon’s argument that it operates as a mere logistics provider.10CNBC. CPSC Says Amazon Responsible for Faulty Goods Sold on Its Marketplace

The ruling covered more than 400,000 products, including faulty carbon monoxide detectors, hairdryers lacking electrocution protection, and children’s sleepwear that failed federal flammability standards. Amazon must notify purchasers and the public of the hazards and provide refunds or replacements. The CPSC found Amazon’s previous efforts, which consisted of safety emails and Amazon credits, “inadequate to protect the public.”11CPSC. CPSC Finds Amazon Responsible Under Federal Safety Law for Hazardous Products Sold by Third-Party Sellers

Amazon said it was “disappointed” and, in March 2025, sued the CPSC in the U.S. District Court for the District of Maryland to overturn the July 2024 ruling and a follow-up January 2025 final order. Amazon calls itself a “third-party logistics provider” exempt from the distributor label, and notes it had already delisted the affected products, notified more than 376,000 purchasers, and issued over $21 million in refunds voluntarily.12Consumer Reports Advocacy. Amazon CPSC Lawsuit Complaint That case is still pending. The CPSC finding does not itself decide any private lawsuit, but it gives injured plaintiffs a federal agency conclusion pointing the same direction as Bolger.

If a Defective E-Bike From Amazon Injured You

A few points follow from the current state of the law.

The state where you file matters. California allows strict liability against Amazon for FBA products. New York does not, at least where Amazon never took possession. Pennsylvania is unsettled. Tennessee allows negligence claims tied to Amazon’s own safety promises even though it rejects strict liability.

How the bike reached you matters too. The cases that go worst for Amazon involve Fulfilled by Amazon: the company stored the product, handled the money, and shipped it. Where the third-party seller ships directly and Amazon never touches the item, courts have been more willing to treat Amazon as a passive platform.

Prior complaints matter. Both the Lewis and Cunanan suits allege Amazon received earlier complaints about the same defect and kept selling. That fact pattern is central to negligent-undertaking theories, because it shows Amazon had notice and did not act on the safety systems it advertises.

Finally, the manufacturer often cannot be reached. Many of the e-bikes in these cases come from Chinese sellers who are effectively judgment-proof from a U.S. courtroom. That is why so much of the litigation focuses on Amazon: for the injured buyer, Amazon is frequently the only defendant with assets in the country.