Narrative Opinion Summary
In this case, plaintiffs James D. and Joyce McLean sued Badger Equipment Company after James was injured due to a malfunction of a sliding lock bar sheet lifter. The jury initially awarded damages to the McLeans, but the court later granted the defendant's motion for judgment as a matter of law on the product liability claim, citing Wisconsin state law. The court determined that the sheet lifter had been substantially modified with a different type of screw, negating the possibility of strict liability as established by the Wisconsin Supreme Court in Glassey v. Continental Insurance Company. Consequently, the court found no credible evidence that the product was sold in its original condition and vacated prior judgments. The court also ordered a new trial on negligence, indicating that liability could still be determined under a negligence theory if specific negligent conduct by Badger could be proven. The motion for a reduction of damages was denied, maintaining the jury's award based on their evaluation of the evidence. Ultimately, the court's decisions enabled Badger to avoid strict liability while allowing for a reassessment of negligence claims, aligning with the policy goals of products liability law.
Legal Issues Addressed
Judgment as a Matter of Law and New Trial Standardssubscribe to see similar legal issues
Application: The court granted Badger's motion for judgment as a matter of law on the product liability claim and a new trial on negligence, while also conditionally granting a new trial on the product liability claim if the judgment is overturned on appeal.
Reasoning: Badger filed a motion for judgment as a matter of law regarding product liability, coupled with an alternative motion for a new trial under Rule 59. The court noted that a new trial under Rule 59 could be granted only if the jury's verdict was against the clear weight of the evidence.
Negligence as an Alternative to Strict Liabilitysubscribe to see similar legal issues
Application: Despite the failure of the strict liability claim, the court ordered a new trial on the negligence issue to determine if Badger Equipment Company was negligent and if that negligence caused McLean's injuries.
Reasoning: Regarding negligence, Glassey allowed for the possibility of liability under a negligence theory if specific negligent conduct could be proven, despite failing to meet the elements of strict liability.
Products Liability under Wisconsin Lawsubscribe to see similar legal issues
Application: The court applied Wisconsin products liability law, which requires proving the product was defective, unreasonably dangerous, and unchanged since leaving the manufacturer. McLean failed to demonstrate that the sheet lifter reached him unchanged, as the original set screw was replaced with a machine screw.
Reasoning: Under Wisconsin products liability law, a plaintiff must establish four elements to prove a product is defectively designed and unreasonably dangerous: 1) the product was defective; 2) the defect made it unreasonably dangerous; 3) the defect existed while under the manufacturer's control; and 4) the product reached the user without substantial change.
Substantial Change in Product Designsubscribe to see similar legal issues
Application: The court found that the substantial modification of the sheet lifter, specifically replacing the set screw with a machine screw, precluded recovery under a strict products liability theory.
Reasoning: This fact, supported by Wisconsin Supreme Court precedent in Glassey v. Continental Insurance Company, precludes recovery. The Glassey decision emphasized that a strict products liability claim necessitates proof that the product had not undergone a substantial and material change since leaving the manufacturer, as such changes negate the plaintiff's ability to establish a prima facie case.