Narrative Opinion Summary
This case involves Seegers Grain Company, Inc. suing United States Steel Corporation (U.S. Steel), Kansas City Millwright Company (KCM), and Design Consultants, Inc. (Design Inc.) following the failure of a steel grain storage tank. Design Inc. settled before trial, and the court granted a directed verdict for U.S. Steel on product liability and struck negligence allegations. The jury found for Seegers against KCM, awarding damages, but acquitted U.S. Steel. On appeal, Seegers challenged the directed verdict favoring U.S. Steel and the dismissal of negligence claims. The appellate court reversed the directed verdict for U.S. Steel, vacated judgments on breach of implied warranty claims, and remanded for a new trial. The steel tank, constructed with U.S. Steel's A283 C plates, failed due to inadequate brittleness warnings. Experts testified the steel was unsuitable for low temperatures. U.S. Steel unsuccessfully argued against liability, stating substantial modifications by KCM and economic loss precluded tort recovery. The court found U.S. Steel liable for selling a defective product without sufficient warning and recognized Seegers' claims for a new trial on negligence and product liability.
Legal Issues Addressed
Breach of Implied Warranty under UCCsubscribe to see similar legal issues
Application: The court ruled that the breach of implied warranty claims should not have been presented to the jury as they involved economic loss, which must be addressed under contract law, not tort law.
Reasoning: The court determined that the existence of an action for res ipsa loquitur and the classification of an action as one for economic or noneconomic loss are both legal questions for the court to decide.
Duty to Warn under Negligence Lawsubscribe to see similar legal issues
Application: U.S. Steel had a duty to warn Seegers about the risks associated with the steel plates, given the known application and previous similar incidents.
Reasoning: The trial court incorrectly ruled that U.S. Steel had no obligation to inform Seegers about the risks of catastrophic failure in their tanks or the results of impact tests related to the Kokomo incident.
Product Liability under Restatement (2d) of Torts, Section 402Asubscribe to see similar legal issues
Application: The court found that U.S. Steel remained liable for selling an unreasonably dangerous product despite KCM's modifications, as the intended use of the steel plates was not altered.
Reasoning: The court found that the intended use of the steel plates—to be welded for constructing a grain storage tank—was not altered by KCM's actions, thus U.S. Steel remained liable for selling an unreasonably dangerous product.
Res Ipsa Loquitur in Product Liabilitysubscribe to see similar legal issues
Application: The court concluded that the catastrophic failure of the grain storage tank resulted in noneconomic loss, leading to the dismissal of breach of implied warranty claims under tort law rather than contract law.
Reasoning: In this case, involving the catastrophic failure of a grain storage tank, the court concluded that the incident resulted in noneconomic loss related to the product.