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Curry v. Louis Allis Co.

Citations: 427 N.E.2d 254; 100 Ill. App. 3d 910; 56 Ill. Dec. 174; 1981 Ill. App. LEXIS 3425Docket: 80-2326

Court: Appellate Court of Illinois; September 24, 1981; Illinois; State Appellate Court

Narrative Opinion Summary

The Illinois Appellate Court affirmed the trial court's summary judgment in favor of the defendants, Louis Allis Company and Central Motor Repair Company, in a products liability case. The plaintiff, who was injured by a falling motor, alleged that the defendants failed to provide adequate warnings about the motor's strength and were liable for his injuries. The court found that Allis, the motor manufacturer, and Central, the seller, were not responsible for the accident since the motor was a general-purpose model that met industry standards and had been improperly installed by the assembler. The court determined that the plaintiff failed to show evidence of a defect at the time of sale or that a defect caused the accident, especially as the motor had been altered. Moreover, the court held that manufacturers of component parts are not liable for safety failures due to improper assembly by others. The defendants were not required to produce the safest possible product, and the practical safety of the motor was deemed sufficient. Consequently, the court upheld the summary judgment, noting the plaintiff's misinterpretation of precedent cases and procedural shortcomings.

Legal Issues Addressed

Alteration of Product and Liability

Application: The plaintiff failed to show the product was defective when sold, as any injury was due to alterations made by the assembler.

Reasoning: The plaintiff failed to provide evidence that the product was defective when sold or that the defect, if present, caused the accident, especially since the product had been altered by the assembler.

Manufacturer's Liability for Component Parts

Application: Manufacturers of component parts are not liable for safety failures due to improper assembly by others, as they lack control over final assembly.

Reasoning: These cases establish that the manufacturer of a final product is responsible for installing safety devices, while component manufacturers lack control over the final assembly and, therefore, cannot be held liable for safety failures due to improper assembly.

Obligation to Produce Safe Products

Application: Defendants are not required to produce the safest possible products but must ensure practical safety under normal use, which was met in this case.

Reasoning: The court concludes that the defendants were not obliged to produce the safest possible product, and the practical safety of the cast iron motor was sufficient.

Products Liability and Duty to Warn

Application: The defendants were not liable for failing to warn about the motor frame's strength since there was no evidence of inadequacy when properly installed, and the parties involved knew the installation requirements.

Reasoning: The plaintiff's claim that Allis and Central failed to warn about the motor frame's strength is dismissed, as there was no evidence presented to prove it was inadequate if installed correctly, and the parties involved were aware of proper installation needs.

Standard for Summary Judgment in Products Liability

Application: Summary judgment was justified as there was no evidence of a defect at the time of sale and the injury was linked to improper installation rather than a product defect.

Reasoning: The trial court awarded summary judgment to Allis and Central, determining that there was no evidence of a breach of duty in manufacturing, designing, or providing warnings.