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Condon v. Carl J. Reinke & Sons, Inc.

Citations: 575 N.E.2d 17; 1991 Ind. App. LEXIS 1170; 1991 WL 131952Docket: 20A04-9006-CV-273

Court: Indiana Court of Appeals; July 15, 1991; Indiana; State Appellate Court

Narrative Opinion Summary

In the case, the plaintiffs, Jeffrey and Deborah Condon, appealed a summary judgment in favor of Gate City Steel and North Star Steel Company following an incident where Jeffrey Condon was injured by a reinforcing bar that shattered. Condon alleged negligence, res ipsa loquitur, strict products liability, and breach of implied warranty of fitness against the general contractor and Gate City, which sought indemnity from North Star, the manufacturer. However, expert testing revealed no defects, attributing the break to repeated bending. The trial court denied summary judgment for the general contractor but granted it for Gate City and North Star, noting Condon's insufficient argument on res ipsa loquitur and breach of implied warranty under Indiana law. The court held that Condon's reliance on an affidavit was inadequate to establish a genuine issue of defectiveness necessary to counter summary judgment. Furthermore, Condon's comparison to a case involving tire defects was unpersuasive, as no evidence suggested a common industry practice creating unreasonable danger. Consequently, the appellate court affirmed the trial court's ruling, finding no material fact in dispute under the existing legal framework.

Legal Issues Addressed

Application of Res Ipsa Loquitur

Application: The court deemed the res ipsa loquitur argument waived due to inadequate argumentation by the plaintiff.

Reasoning: The court noted that Condon did not adequately argue the res ipsa loquitur theory, waiving that issue.

Breach of Implied Warranty under Indiana Law

Application: The court found this claim meritless as Indiana law subsumes breach of implied warranty under strict liability.

Reasoning: The court noted...found the breach of implied warranty argument meritless, as Indiana law treats it as subsumed under strict liability.

Expert Testimony in Product Defect Cases

Application: The expert testimony provided did not support the claim of defectiveness, as tests revealed no defects in the reinforcing bar.

Reasoning: Testing conducted by experts revealed no defects in the reinforcing bar; the break was attributed to repeated bending.

Negligence and Products Liability Claims

Application: The plaintiff's reliance on an affidavit failed to establish a defect in the product, insufficient to overcome summary judgment in favor of the defendants.

Reasoning: Condon's reliance on Edward Neidlinger's affidavit was insufficient to create such an issue regarding his negligence and products liability claims, as it did not establish the defectiveness of the reinforcing bar involved.

Summary Judgment Standards under TR 56(E)

Application: In this case, the court found that the moving party for summary judgment must present specific facts to demonstrate a genuine issue for trial, and the plaintiff failed to do so.

Reasoning: Under TR 56(E), a party moving for summary judgment cannot rely solely on the allegations or denials in their pleadings; they must present specific facts demonstrating a genuine issue for trial.