The United States District Court for the Western District of Missouri recently denied Whirlpool’s Motion for Summary Judgment on Plaintiff’s claims that a Whirlpool manufactured refrigerator caused a fire in Plaintiff’s home.  Whirlpool had moved for summary judgment on the basis that Plaintiff’s expert had failed to follow the “scientific method” required by NFPA 921.  The Court recognized that NFPA was considered a guide and, while some Courts had recognized it was useful in investigating fires, it was not the only acceptable methodology that could be employed in conducting an origin and cause investigation.  In making its ruling the Court also considered the opinion of Plaintiff’s other expert that had made a determination of the point of origin but could not rule out the outlet behind the refrigerator as potential competent ignition source.