Brief Fact Summary. Despite warnings from the manufacturer, Hood (Plaintiff) removed a guard on a miter saw. The blade flew off and Plaintiff was injured.
Synopsis of Rule of Law. An adequate warning need not always explain in encyclopedic detail what will happen if a warning is not followed.
Issue. Must an adequate warning always explain what will happen if a warning is not followed?
Held. No. Judgment affirmed.
* Maryland does not require an encyclopedic warning; a warning need only be one that is reasonable under the circumstances. A manufacturer need not warn of every mishap or source of injury that the mind can imagine that could flow from a product.
* Plaintiff assumes that the cost of a more detailed warning label is minimal and claims that such a warning would have prevented his injuries. However, this ignores the effect that such detailed warnings have on consumers and users of products; detailed warnings undermine the effectiveness of them and the warning losses its communicative value.
* In this case, Defendant’s warnings were clear and numerous. The warnings said that “serious injury” could result from the removal of the guards. These warnings were conspicuous and acknowledged by Plaintiff when he removed the guards.
* Furthermore, it is not likely that someone would remove the guards. There has only been one similar accident in the last fifteen years.
Discussion. In this case, the warnings were held to be adequate. The adequacy of the warnings was sufficient. It was Plaintiff who removed the guards and decided to operate the saw. Plaintiff is responsible for his own actions, which resulted in his injuries.