Jackson v. Corning Glass Works

Citations: 538 A.2d 666; 1988 R.I. LEXIS 22; 1988 WL 19224Docket: 86-354-A

Court: Supreme Court of Rhode Island; March 9, 1988; Rhode Island; State Supreme Court

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In the case Kenneth F. Jackson v. Corning Glass Works, the Supreme Court of Rhode Island addressed an appeal by Corning against a judgment awarding the plaintiff, Kenneth F. Jackson, $804,892.17 for injuries sustained when a shard of glass from a Pyrex lid struck his eye. The incident occurred when Jackson's wife stacked several Corning Ware bowls and their glass lids in a pyramid formation on a slightly tilted shelf in a kitchen cupboard. The bottom of the stack included a roasting pan that extended beyond the shelf edge. On January 13, 1979, when Jackson closed the cupboard door, the pan was nudged upward, causing the entire stack to topple. Jackson lost sight in his right eye as a result of the incident.

At trial, evidence was presented showing that Corning's promotional materials depicted similar stacking methods without warnings against such practices. Expert testimony indicated that the way the Corning Ware was stacked was unstable, particularly under the conditions of the cupboard. The Supreme Court ultimately reversed the judgment in favor of the plaintiff, indicating that the stacking method used was a contributing factor to the accident.

Doctor Bucciarelli criticized the design of the lids as defective, claiming that the bowls placed on them lacked a stable base, leading to potential toppling under lateral force. At the trial's conclusion, Corning sought a directed verdict on all counts, which was granted except for the seventh count alleging strict liability. The jury ruled in favor of the plaintiff, awarding $1,263,567 but attributing 65 percent of the responsibility for the injury to the plaintiff, which reduced the verdict to $442,248.45. After adding interest, the final judgment was $804,892.17. Corning's appeal focused on whether it was entitled to a directed verdict based on the claim that its products were not unreasonably dangerous. The court noted that when considering such motions, all evidence must favor the opposing party, and a directed verdict is warranted if legally insufficient evidence exists to support the plaintiff's recovery. The legal framework for strict liability, as established in previous cases, requires that a product must be in a condition not anticipated by the consumer and poses an unreasonable danger at the time it leaves the seller's control. The definition of "unreasonably dangerous" implies a substantial likelihood of injury to the user, factoring in the user's awareness of potential dangers.

The legal approach aims to safeguard consumers unaware of the dangers associated with a product's intended use or normal handling. It does not extend protection to users who employ the product contrary to its intended purpose or who are aware that specific precautions are necessary for safe use. In this case, it is undisputed that the Corning Ware and Pyrex lids were stacked in an unstable pyramid on a shelf with a ridge, and the bottom pan may have slightly overhung the shelf edge. No expert testimony provided credible evidence regarding the force applied when the cupboard doors closed. Furthermore, there was no alternative safe design presented. It is common knowledge that cookware can break when falling on a hard surface and that a tall stack of dishes is at risk of toppling if laterally disturbed. Thus, allowing a jury to determine the design's defectiveness was a legal error. The case draws a parallel to a previous ruling where the absence of decals on a glass door was not deemed a design flaw due to the obvious risk of collisions with glass doors. The court concluded that consumers should recognize the hazards of stacking glass items and must take precautions for stability. The manufacturer could not have anticipated such misuse or provided feasible safety measures. Consequently, the trial court’s failure to grant a directed verdict on the strict liability count was erroneous, leading to the reversal of the judgment in favor of the defendant, Corning.