Citation. Hood v. Ryobi Am. Corp., 181 F.3d 608, CCH Prod. Liab. Rep. P15,556 (4th Cir. Md. June 23, 1999).
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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.
Plaintiff purchased a miter saw made by Ryobi (Defendant). Warnings were clearly posted on the saw, which indicated the user should operate the saw only when the blade guards are in place. The day after the purchase, Plaintiff began to use the saw but found that the blade guard prevented the blade from passing through a piece of wood that was four inches in height. Plaintiff removed the guards despite the warnings. The warnings were explicit but did not tell the operator why or how injury would occur if the guards were removed. With the guards removed, Plaintiff used the saw and was injured when the blade flew off the saw; Plaintiff’s thumb was partially amputated and his right leg was lacerated. Plaintiff admits that he read the owner’s manual and most of the warning labels before using the saw. He claims however that he believed the blade guards were intended solely to prevent a user’s clothing or fingers from coming into contact with the saw. Plaintiff contends that he was
unaware that removing the guards would cause the spinning blade to detach from the saw. Plaintiff sued Defendant for products liability for failure to warn and defective design. The court entered summary judgment for Defendant finding that in the face of adequate warnings, Plaintiff altered the saw and caused his own injury. Plaintiff appealed.
Must an adequate warning always explain what will happen if a warning is not followed?
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.
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.