Knitz v. Minster Machine Co.

Supreme Court of Ohio · Torts

TortsProducts liabilityStrict liabilityDesign defectSummary judgmentdesign defectstrict liabilityconsumer expectation

Facts

The plaintiff was injured while using the defendant manufacturer's press. She presented evidence that the press design allowed accidental tripping of a foot pedal control and lacked a point of operation guard when the foot pedal was operative. An affidavit from a former safety engineer stated the press was defective because it lacked adequate guarding at the point of operation and inadequate guarding of the foot pedal to prevent inadvertent tripping. The plaintiff's deposition indicated the accident occurred when she tried to pull the foot switch toward her with her foot and did not intend to activate it.

Issue

Whether summary judgment for the manufacturer was proper on the plaintiff's strict liability design-defect claim. More specifically, the court had to determine the proper legal standard for strict liability based on defective product design and whether the plaintiff's evidence created a genuine issue of material fact under that standard.

Rule

A product design is in a defective condition to the user or consumer if either: (1) it is more dangerous than an ordinary consumer would expect when used in an intended or reasonably foreseeable manner; or (2) the benefits of the challenged design do not outweigh the risk inherent in that design. Relevant factors in evaluating defectiveness include the likelihood that the design will cause injury, the gravity of the danger posed, and the mechanical and economic feasibility of an improved design.

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

In Toledo, Avery Cole lost two fingers while using a sheet-cutting machine manufactured by Lakefront Fabrication Systems. Avery offers evidence that the machine’s hand-activation layout made accidental cycling possible and that a simple guard would have reduced the danger, while the manufacturer argues the machine performed exactly as intended.

Under the governing strict-liability design-defect rule, which is the strongest statement of Avery’s burden?

Explanation. The majority adopted a strict-liability design-defect standard with two alternative routes: consumer expectations or risk-benefit balancing. It rejected using negligence reasonableness as the governing strict-liability standard and also stated that strict liability does not require a separate showing that the defect was 'unreasonably dangerous.' (Derived from Knitz v. Minster Machine Co. (n.d.).)