Gray v. Badger Mining Corp.

Brief Fact Summary.

The Minnesota Supreme Court held that a supplier of products legally has a duty to issue a warning regarding any reasonably foreseeable dangers that could cause an injury as a result of using the product. 

Synopsis of Rule of Law.

There is a legal duty to all suppliers of products in Minnesota to issue a warning regarding all foreseeable injuries that could result from a danger posed by the product. 

Facts.

Badger Mining Corporation (Defendant) provided Smith Foundry with sand to be used to create molds. An employee of Smith Foundry named Lawrence Gray (Plaintiff) is suing the defendant for failing to warn plaintiff of the danger posed of being exposed to the sand. Plaintiff was diagnosed with silicosis of the lungs which is believed to have been caused by the exposure of the sand. At trial, the plaintiff proved the defendant was aware of the dangers when the sand was used for this purpose. At trial, Defendant moved for summary judgment and was denied. Defendant appealed where the appellate course reversed stating there was no legal duty to disclose the warning. Plaintiff appeals. 

Issue.

In Minnesota, does a supplier of products have a legal duty to issue a warning regarding any potential dangers the product poses where a reasonably foreseeable injury could occur? 

Held.

Yes. Looking at the restatement of torts, the court determined that a supplier has a legal duty to disclose any dangers the product may pose and can be liable for failing to warn the user of the product of the danger the product posed even if used correctly. 

Discussion.

The court issues a handful of exceptions to liability. The first, is if the user should be aware of the danger of the product. They use an example involving chemicals where anyone who uses chemicals knows the dangers posed in using the chemicals. A second defense, is if the supplier does prove that he provided adequate warning of the product’s danger to cause injury and an injury results that is similar to the warning provided. Finally, if a supplier provides only raw materials that are used to create another product then the supplier of raw materials is free from liability.