The Supreme Court of Tennessee addresses certified questions from the U.S. District Court regarding a products liability case involving William J. Snyder and defendants LTG Lufttechnische GmbH, LTG Technologies, Inc., and HSM Pressen GmbH. The court accepted two questions: (1) whether defendants can present evidence that the plaintiff's employer contributed to the plaintiff’s injuries due to alterations or improper maintenance of the product, and (2) the implications of Tenn. Code Ann. § 29-28-108 if the answer to the first question is "no." The court concludes that defendants may introduce such evidence, allowing the jury to consider the employer's actions in determining causation, though they cannot assign fault to the employer. As a result, the second question is deemed unnecessary.
The case involves Snyder, a technician at Sara Lee Knit Products, who was injured while working on a cotton baler that had malfunctioned. Snyder inserted his arm into the machine without disconnecting power to clear cotton from a protective switch, resulting in injury. He filed a products liability suit against the manufacturers of the baler, with the Travelers Insurance Company intervening for subrogation claims related to workers' compensation.
The plaintiff seeks damages for personal injury based on strict liability in tort, negligence, and breach of warranty, alleging that the defendants negligently designed and manufactured a cotton baler, failed to warn about its dangers, and breached warranties. The defendants counter that the baler was state-of-the-art, not defective or unreasonably dangerous when it left their control. They assert that the plaintiff's employer altered the machine by removing a safety panel, which they argue constitutes an intervening act of negligence that caused the injuries. Under Tenn. Code Ann. § 29-28-108, a manufacturer is not liable if a product becomes unreasonably dangerous due to unforeseeable alterations or improper maintenance after leaving their control. The defendants reference Tenn. Code Ann. § 29-28-105, stating that liability arises only if a product is defective or unreasonably dangerous at the time it leaves the manufacturer. The removal of the protective panel and subsequent improper maintenance violated safety instructions. The United States District Court for the Eastern District of Tennessee has certified two questions regarding the case, noting that prior rulings, particularly Ridings v. Ralph M. Parsons Co., may limit the defendants' ability to argue that the employer's actions contributed to the plaintiff's injuries. In McIntyre v. Balentine, Tennessee adopted a modified comparative fault system, allowing recovery if the plaintiff's negligence is less than the defendant's, with damages reduced proportionately. The implications of this system for tort litigation are recognized, and further harmonization of legal principles will be addressed in the future, especially in light of the Ridings case's relevance to employer liability in products liability claims.
In Ridings, a plaintiff injured from a fall while working filed a third-party tort claim against the ladder's manufacturer and distributor, citing negligence and strict liability. The defendants sought to assert an affirmative defense, claiming the plaintiff's employer contributed to the injuries, raising the question of whether the employer, shielded from tort liability by Tennessee's workers’ compensation law, could be included in fault apportionment in the tort action. The defendants argued that allowing attribution of fault to the employer would reduce their liability without imposing legal responsibility on the employer, aligning with the principle from McIntyre that liability corresponds to the percentage of damages caused by each party. Conversely, the plaintiff contended that attributing fault to an immune employer violated McIntyre's principle of proportionality in damage reduction. The court ruled against the defendants, emphasizing that fault could only be assigned to parties liable in tort, reaffirming that the employer's conduct should not influence the plaintiff's recovery. The court's decision was based on the underlying policies of the workers’ compensation system and comparisons with other jurisdictions. The defendants in the current case argue that Ridings was wrongly decided, asserting that it contradicts McIntyre's fairness objective since they bear the fault percentage that would have been assigned to the employer. However, the court reiterated that only parties against whom the plaintiff has a valid tort claim should be held accountable for fault.
The plaintiff’s employer is immune from being a party in the plaintiff’s tort action for personal injuries sustained during employment, preventing any attribution of fault to the employer. This aligns with the principles established in the case of Ridings, which emphasized fairness and efficiency in determining fault. The doctrine of comparative fault restricts fault assessments to parties against whom the plaintiff has a valid claim. The court affirmed that the employer cannot be deemed the proximate cause of the injuries due to statutory immunity under Tenn. Code Ann. 50-6-108(a), although the employer could be considered the cause in fact. The distinction between "cause in fact" and "proximate cause" is crucial; the former relates to direct cause-and-effect relationships, while the latter involves policy decisions regarding legal liability. Evidence regarding the employer’s actions that may have contributed to the injuries can be presented at trial, but jurors cannot assign legal fault to the employer. The jury will be instructed to consider the employer's actions only in relation to the plaintiff's burden of proof against the defendants, without assessing the employer’s fault. Additionally, jurors will be informed that the employer’s legal responsibility will be addressed separately. The opinion will be transmitted according to the relevant court rules, with costs taxed to the defendants.
