Hughes v. Magic Chef

Supreme Court of Iowa · Torts

TortsProducts liabilityStrict liabilityJury instructionsMisuseAssumption of riskstrict liabilitysection 402A

Facts

Hughes was severely burned when a Magic Chef stove exploded in his mobile home. After the propane tank had run dry and was later refilled, two top pilot lights were relit but the oven broiler pilot light was not; experts testified propane then built up in the stove and ignited when Hughes attempted to use it two days later. Hughes sued on strict liability, alleging the stove was unreasonably dangerous, and Magic Chef raised assumption of risk and misuse of product. The appeal concerned the correctness of the jury instructions rather than resolution of the factual dispute over the explosion's cause.

Issue

Whether the trial court's jury instructions misstated Iowa strict products liability law by requiring Hughes to prove the defect was not discoverable by ordinary inspection, by submitting misuse as an affirmative defense and focusing on Hughes' personal knowledge, and by instructing on assumption of risk without requiring awareness of danger and unreasonable encounter with that danger.

Rule

In a strict products liability action, the plaintiff need not prove that the defect was not discoverable by ordinary inspection; mere failure to discover a defect is not a defense. Misuse is not an affirmative defense but part of the plaintiff's burden to prove that the product was unreasonably dangerous in a reasonably foreseeable use. Assumption of risk remains an affirmative defense, but it applies only when the plaintiff voluntarily and unreasonably proceeds to encounter a known danger, with actual awareness of the danger.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Des Moines, Nora Kim bought a new space heater manufactured by Prairie Crest Appliances, a fictional company. The heater later emitted a burst of flame because of an internal valve defect that a careful consumer could likely have noticed by opening the back panel and examining the valve assembly before first use.

In Nora's strict products liability suit, Prairie Crest requests a jury instruction requiring Nora to prove the defect was not discoverable by ordinary inspection. How should the court rule?

Explanation. The majority held it is error to require a strict liability plaintiff to prove the defect was not discoverable by ordinary inspection. Mere failure to discover a defect or guard against its existence is not a defense in strict liability; only assumption of risk may bar recovery. Thus the requested instruction would improperly insert contributory-negligence-type reasoning into strict liability. (Derived from Hughes v. Magic Chef (n.d.).)