Prentis v. Yale Mfg. Co.

Brief Fact Summary.

Plaintiff was injured in an accident involving the operation of a hand-operated forklift that was manufactured by defendant. Plaintiff brought a products liability suit, alleging that the forklift contained a design defect.

Synopsis of Rule of Law.

In a products liability suit against a manufacturer that is based on defective design, the jury need only be instructed on a single unified theory of negligent design.

Facts.

John Prentis (plaintiff) was a foreman at a car dealership. To perform his work, Prentis used a forklift manufactured by Yale Manufacturing Company (“Yale”) (defendant). The forklift was a stand-up or walking type as opposed to a riding or sit down type. The forklift weighed about two thousand pounds and was powered by a battery that needed to be recharged every night. The forklift was also equipped with a “dead-man” switch that prevented it from moving if the operator let go of the handle or controls. One day, Prentis was using the forklift while the battery was running low as he was loading cargo into a van. While operating the forklift, Prentis lost his footing and fell. The forklift ran past Prentis and hit a parked car. Prentis sustained a hip injury that was determined to have been a result of the fall only. He brought suit against Yale based on an alleged defect in the design of the forklift.

Issue.

Whether the trial judged erred by refusing to instruct the jury on breach of warranty in a products liability suit based on defective design?

Held.

No. In this products liability suit against Yale for an alleged defect in the design of its products, the trial judge did not err in refusing to instruct the jury on breach of warranty. Such an instruction would have been misleading, created confusion, and led to prejudicial error. The judgment of the appellate court is reversed, and the judgment of the trial court is reinstated.

Discussion.

There are four approaches for determining the meaning of “defect” in design cases: (1) a negligence risk-utility analysis; (2) a comparison of the risk and utility of the product at the time of trial; (3) a focus on consumer expectations about the product; and (4) a combination of the risk-utility and consumer-expectations tests. Most courts use the risk-utility analysis. Under this analysis, the jury considers the alternatives and risks the manufacturer faced and determines whether, in light of these alternatives and risks, the manufacturer exercised reasonable care in making its product design choices. While some jurisdictions say that the risk-utility analysis precludes a negligence calculus, the court finds such a preclusion unpersuasive. The court looks to the formula set forth in the Model Uniform Product Liability Act (“UPLA”), which adopts a negligence system with respect to design defects. Likewise, the court adopts a pure negligence, risk-utility test in products liability actions against manufacturers predicated upon defective design.