Narrative Opinion Summary
This case involves a lawsuit filed by a plaintiff against a crane manufacturer, alleging severe injuries due to a defectively designed or manufactured crane, invoking strict liability. The defendant sought summary judgment, citing Ohio's statute of repose, which bars claims for bodily injury related to defective improvements to real property filed more than ten years post-installation. The crane, installed in 1926 and used continuously, was deemed an improvement to real property, thus falling under the statute's protection. The plaintiff argued that the defendant should be exempt as a 'materialman,' a category not subject to the statute. However, the court determined that the defendant was not a 'materialman,' as the crane was uniquely designed for the site, and thus not exempt. The court granted summary judgment for the defendant, effectively barring the plaintiff's claim as it was initiated beyond the statutory period.
Legal Issues Addressed
Definition of 'Improvement to Real Property'subscribe to see similar legal issues
Application: The court found that the crane, permanently affixed to the plant and integral to operations, met the criteria for an improvement to real property, enhancing the value of the property.
Reasoning: The crane in question is permanently affixed to the plant, moving on rails attached to the building's walls, and is deemed an 'improvement to real property' under Ohio law, enhancing the property's value.
Exemption for Materialmen under the Statute of Reposesubscribe to see similar legal issues
Application: The court determined that the defendant was not a 'materialman' as it manufactured a uniquely designed crane specifically for the site, thus not qualifying for the exemption from the statute of repose.
Reasoning: Consequently, the court concludes that the defendant does not fall under the 'materialman' category and is thus protected by the Ohio statute of repose.
Statute of Repose under Ohio Rev. Code Ann. § 2305.131subscribe to see similar legal issues
Application: The defendant successfully argued that the plaintiff's claim was barred by the Ohio statute of repose, as the crane was deemed an improvement to real property and the claim was filed more than ten years after its installation.
Reasoning: Harnischfeger moved for summary judgment, asserting that Hall's claim is barred by Ohio Rev. Code Ann. § 2305.131, the state’s statute of repose, which prohibits actions for bodily injury arising from a defective improvement to real property more than ten years after the improvement's construction or service provision.
Strict Liability in Product Defectssubscribe to see similar legal issues
Application: The plaintiff sought recovery under strict liability for injuries caused by the alleged defective design or manufacture of the crane, which purportedly lacked a warning system.
Reasoning: Hall claims that the crane was defectively designed or manufactured, specifically lacking a warning system, and seeks recovery under strict liability for injuries caused by its defective condition.