Brief Fact Summary. Plaintiff brought a product liability action to recover damages for an injury he sustained while using a plastic cutting machine made by Spadone Machine Co. (Defendant). The Superior Court of New Hampshire entered the jury verdict in favor of the employee. The company appealed, claiming that the evidence did not support the verdict as conduct by Plaintiff and other company employees was a superseding cause.
Synopsis of Rule of Law. A jury could properly find that a defect is a proximate cause of an injury. The existence of concurrent causes will not in and of itself vitiate a finding that one cause was a proximate cause of the injury.
The Bartlett Court concluded that under New Hampshire's law, § 402A imposed a duty upon a product manufacturer to design his product reasonably safely for the uses which he can foresee.View Full Point of Law
Issue. Did the trial court err in disallowing Defendant’s superseding cause argument for submission to the jury?
Held. No. The Supreme Court of New Hampshire held that the jury’s general verdict in favor of the employee constituted a finding that the machine was defective in design, unreasonably dangerous, and the proximate cause of the employee’s injuries.
Discussion. Defendant claimed that the employer, Davidson Rubber, was aware of the manner in which its employees used the device in question, and it contended that this knowledge and practice was a superseding cause of the injury suffered by Plaintiff. In considering the manufacturer’s claims, the court rejected this argument. Generally, a manufacturer is under a general duty to design a product, which is reasonably safe its foreseeable uses. In this case, Defendant cannot successfully argue that a third person’s negligence or misuse was a superseding cause, he must prove that the negligence or misuse was not reasonably foreseeable. This Defendant failed to do provide evidence to this effect.