You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Craft v. Wet'N Wild, Inc.

Citations: 489 So. 2d 1221; 11 Fla. L. Weekly 1339; 1986 Fla. App. LEXIS 8309Docket: 85-995

Court: District Court of Appeal of Florida; June 12, 1986; Florida; State Appellate Court

Narrative Opinion Summary

In this case, the appellant challenged a trial court's decision granting judgment on the pleadings in favor of the defendant, a water park company, over a strict liability claim. The appellant, who sustained injuries on a water slide owned by the company, argued that a defect in the slide warranted a strict liability cause of action. However, the court affirmed the trial court's ruling, emphasizing that strict liability does not extend to structural improvements to real property, such as the on-site constructed water slide. The court reasoned that the slide, made of soil and concrete, was more akin to a building foundation than a standalone product, thus not meeting the criteria for strict liability. The court cited case law to support its conclusion that defects in structures are not equivalent to defects in products incorporated into them. The appellant's separate claim of negligent design was acknowledged but not considered in this appeal. The decision was affirmed, with a special concurrence highlighting the nature of the construction as pivotal. The outcome denied the strict liability claim, leaving the appellant without relief on these grounds.

Legal Issues Addressed

Definition of Product under Strict Liability

Application: The court found that the water slide, being constructed in place with soil and concrete, did not constitute a product subject to strict liability.

Reasoning: Judge Dauksch concurring specially, explaining that the water slide's construction—comprising soil and concrete—rendered it more akin to a building foundation than a product subject to strict liability.

Differentiation between Structure and Product

Application: The court differentiated between a defect in a structure itself and a separate product incorporated into it for the purposes of strict liability.

Reasoning: The defect pertains to the structure itself rather than a separate product incorporated into it.

Strict Liability for Structural Improvements

Application: The court determined that strict liability does not apply to defects in structural improvements to real property, such as water slides constructed on-site.

Reasoning: The court upheld the trial judge's ruling, concluding that strict liability principles do not apply to structural improvements to real property.