Hood v. Ryobi America Corp.

Brief Fact Summary.

Despite reading the operator’s manual and stickers on the saw warned that users should only operate the saw with the blade guards in place or risk serious personal injury, Hood nonetheless detached the blade guards. The saw blade flew off, injuring Hood.

Synopsis of Rule of Law.

A manufacturer may be liable for placing a product on the market that bears inadequate instructions and warnings or that is defective in design.

Facts.

Hood purchased a Ryobi saw for house repairs. The saw blade was shielded nearly entirely by blade guards, the top half of which was metal and the lower half of which was a transparent plastic guard that retracted into the upper guard as the saw came into contact with the work piece. A number of warnings in the operator’s manual and affixed to the saw itself stated that the user should only operate the saw with the blade guards in place or risk serious personal injury.

Despite having read the operator’s manual and seen the warnings affixed to the saw, Hood detached the blade guards when he was unable to cut a piece of wood completely and then continued to operate the saw without the blade guards for another 20 minutes, at which time the saw blade flew off the saw and partially amputated his left thumb and lacerated his right leg.

Hood contends that he was unaware that removing the blade guards would permit the spinning blade to detach from the saw and that he believed that the blade guards were solely intended to prevent a user’s clothing or fingers from coming into contact with the saw blade.

Issue.

1. Did Ryobi fail to adequately warn of the dangers associated with using the saw blade without the blade guards?
2. Was the design of the saw defective?

Held.

Affirmed.

1. No. Ryobi provided adequate warning of the dangers of using the saw without the blade guards in place.
2. No. The design of the saw was not defective.

Discussion.

Hood contends that an adequate warning would have explained the consequences of removing the blade guards (i.e., that the blade itself would detach). However, Maryland’s law requires not an encyclopedic warning, but rather a clear and specific warning, where the costs to change the warning outweigh the benefits of providing more detail to the warning.

Here, the price of more detailed warnings goes beyond the additional printing fees. Studies show that excessive detail in warnings can undermine the effectiveness of the warnings altogether because the warnings become too long and technical to understand for the average consumer.

Ryobi’s warnings are clear and unequivocal. At least nine warnings in the operator’s manual and affixed to the saw warn the user not to operate the saw without the blade guards. For the ordinary user, these warnings would be sufficient to prevent the injury that occurred here, as has been indicated by data that shows only one similar accident occurred in the last 15 years.