Manufacturers need not design accident-proof machines or warn against obvious dangers
A Minnesota hog farming operation, VZ Hogs LLP, uses an extruder manufactured by Sebright Products, Inc., to separate liquids from solid mass. When the extruder jammed, several workers tried to unjam it. The employer never trained them how to unjam the machine. Nereus Montemayor climbed into the machine while it was still connected to its power source, contrary to written warnings (and common sense). Another employee, unaware Montemayor was inside the machine, turned it on. Montemayor’s legs were crushed. The employer clearly failed in its duty to train the employees and was subsequently fined for serious state OSHA violations. After recovering workers’ compensation benefits, Montemayor sued the extruder manufacturer. His case, Montemayor v. Sebright Products, Inc., alleges that Sebright negligently failed to warn of the danger of being within the machine, and that the extruder was defectively designed. While recognizing that this tragic accident could have been prevented if the employer trained the workers or any of them had followed the instructions for repairing the machine, both the trial and appellate court ruled in favor of Sebright on the grounds that it was not foreseeable that a worker would place his entire body within the machine without first disconnecting the power source, and that another worker would then turn on the machine.
The Minnesota Supreme Court agreed to review the case and PLF filed an amicus brief in support of Sebright. We argue that a manufacturer has no duty to warn (beyond the extensive warnings already provided both on the surface of the machine and in the operations manual) in these circumstances and the machine was not defective; it began operating only because a worker turned it on and no one had disconnected the power supply. Public policy cautions against expanding manufacturer liability to the circumstances present in this case. A manufacturer cannot be held liable for injuries that arise from a person’s decision to misuse a product in an obviously dangerous manner and against manufacturer warnings. This limit on liability protects producers from being held responsible for accidents that are outside of their control, or more fairly attributed the user (and, in this case, the employer). This approach is not only legally sound, it advances important fairness and efficiency policies by ensuring that manufacturers do not waste time and money trying to achieve an unrealistic level of safety before marketing useful products, and that those truly at fault for injuries bear the cost of their actions.
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