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Clarence Haines v. Powermatic Houdaille, Inc.
Citations: 661 F.2d 94; 1981 U.S. App. LEXIS 17027Docket: 81-1010
Court: Court of Appeals for the Eighth Circuit; October 8, 1981; Federal Appellate Court
Clarence Haines sustained severe injuries while operating a Powermatic Houdaille table saw at a Coast Guard carpentry shop in St. Louis, Missouri, in May 1978. The injury occurred when Haines, using the saw without its blade guard, was guiding a board that kicked back, causing his left hand to contact the blade. As a result, Haines became partially disabled and left the Coast Guard as a Temporary Disabled Retiree. Haines subsequently filed a lawsuit in state court against Powermatic, alleging that the saw was defectively designed, creating an unreasonable risk of harm. Specifically, he claimed that the design required the removal of the blade guard for certain operations and that there were no warnings regarding the dangers of operating the saw without it. The case was transferred to federal court, where it was tried before a magistrate with the consent of both parties, and the jury ultimately ruled in favor of Powermatic. Haines appealed, arguing that the magistrate erred by denying his motion for a mistrial after making an inappropriate comment about Haines' prior knowledge of the blade guard and by instructing the jury on the absence of a duty to warn and Haines' voluntary exposure to risk. The appellate court noted that although the magistrate incorrectly stated that Haines had knowledge of the guard, he promptly instructed the jury that his comments were not evidence. The court concluded that the repeated cautionary instructions sufficiently mitigated any potential prejudice from the magistrate's error, affirming the denial of the mistrial motion and the jury's verdict in favor of Powermatic. Haines acknowledged his awareness of the potential for injury from an unguarded saw blade but argued that he did not voluntarily and unreasonably expose himself to the risk because he was unaware that the saw could cause a board to kick back into the blade. He claimed the magistrate erred by instructing the jury on the absence of a duty to warn and contributory fault, asserting no supporting evidence existed for this defense. However, the court found sufficient evidence indicating that the dangers of using the unguarded saw were open and obvious, and that Haines had voluntarily and unreasonably engaged with a known risk. Testimony from a carpenter revealed that Haines had previously used the saw with the guard in place, was aware the guard was removed at the time of the accident, and had been warned not to operate the saw alone. Additionally, a warning sign against using the saw without a guard was posted. Under Missouri law, a manufacturer is not liable to warn against dangers that are apparent or known to the plaintiff, and contributory fault applies when a plaintiff unreasonably encounters such risks. The court concluded that sufficient evidence justified the magistrate's jury instructions, affirming the trial court's decisions.