Knitz v. Minster Machine Co

Brief Fact Summary.

The Court of Appeals for Lucas County (Ohio) affirmed the trial court’s grant of summary judgment to the manufacturer of a punch press. Appellant, a machine operator, had filed a products liability action against Minster Machine Co. (Appellee) after her fingers were amputated. Appellant sought review.

Synopsis of Rule of Law.

A product design is in a defective condition to the user or consumer if (1) it is more dangerous than an ordinary consumer would expect when used in an intended or reasonably foreseeable manner; or (2) if the benefits of the challenged design do not outweigh the risk inherent in such design.

Facts.

Appellant, using the punch press, leaned on the bolster plate in order to move the foot pedal back in place with her foot. In so doing, she activated the foot pedal, and the machine came down on her hand, and amputated two fingers. A button-tripping device, which required two hands, had been disconnected, and the operator did not have a pullback guard attached to her wrists. Plaintiff claimed that the press was inherently defective, and thus dangerous to any user.

Issue.

Did the lower court err in granting summary judgment?

Held.

Yes. The court reversed the summary judgment that was granted in favor of the Appellee and remanded the case. The court applied the risk-benefit test and held that Appellee presented genuine issues of fact, based on expert opinions, as to whether the press design was defective by allowing accidental tripping of the foot pedal control and in failing to provide a point of operation guard when the foot pedal was operative.

Dissent.

The dissent succinctly states: “[t]he majority opinion would render the manufacturer of any machinery absolutely liable for any and all injuries received by the user however careful the company may be in the design of the product and however careless the individual might be in the use thereof. This should not be the law.” The dissent takes the view that personal responsibility should complement corporate responsibility, placing the onus on the individual: “[h]ad appellant followed the instructions and warnings, this unfortunate accident would not have occurred.”

Discussion.

An action for product liability will invariably rest upon one of four theories of tort law: (1) negligence; (2) breach of one or more warranties; (3) strict products liability; or (4) misrepresentation. With regard to the third, examined here, the court explained: “[t]he policy underlying strict liability in tort requires that a product may be found defective in design, even if it satisfies ordinary consumer expectations, if through hindsight the jury determines that the product’s design embodies excessive preventable danger, or, in other words, if the jury finds that the risk of danger inherent in the challenged design outweighs the benefits of such design.”
The court then outlined the specific considerations in determining defectiveness: “Factors relevant to the evaluation of the defectiveness of the product design are the likelihood that the product design will cause injury, the gravity of the danger posed, and the mechanical and economic feasibility of an improved design.”
Here, the issue was simpler: was summary judgment proper if what was required was a factual determination based on the considerations noted above? The Knitz court outlined the standard summary judgment analysis: “[s]ummary judgment shall be rendered if there is no genuine issue as to any material fact; if the moving party is entitled to judgment as a matter of law; and if it appears from the evidence that reasonable minds can come to but one conclusion and that conclusion is adverse to the party against whom the motion for summary judgment is made, such party being entitled to have the evidence construed most strongly in his favor.” Thus, summary judgment was improper.