James Allen, Sharon Allen v. Verson Allsteel Press

Citations: 957 F.2d 275; 1992 U.S. App. LEXIS 2689; 1992 WL 35404Docket: 91-1156

Court: Court of Appeals for the Sixth Circuit; February 27, 1992; Federal Appellate Court

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James and Sharon Allen appealed a summary judgment in favor of defendant Verson Allsteel Press regarding an injury James Allen sustained from a defectively designed power press. The injury occurred on September 18, 1987, while Allen was performing lubrication duties at Lobdell-Emery Manufacturing Co. He climbed onto a rail to fill the oil reservoir of the press and, while stabilizing himself at an unguarded "pinch point," was crushed by the activated piston, resulting in the loss of three fingers.

The press, manufactured in 1965, had undergone modifications that altered the original method of filling the oil reservoir, now requiring access from above, which was eight and a half feet high, adjacent to the unguarded pinch point. Verson's motion for summary judgment argued that the Allens failed to demonstrate a prima facie case of design defect, asserting that the circumstances of the injury were not foreseeable.

The plaintiffs contended that the press was inherently dangerous and did not comply with industry safety standards, claiming Verson had a duty to warn about foreseeable modifications. The district court ruled that under Michigan law, the key issue in design defect claims is whether the manufacturer exercised reasonable care regarding foreseeable uses that could lead to injury. The court noted that the safety standards cited by the plaintiffs were established after the press was sold and that the standards in effect at the time of sale did not require guarding for parts above eighty-four inches, which Verson’s design exceeded.

The district court ruled in favor of Verson on the foreseeability element, asserting that the evidence did not warrant jury deliberation due to three main reasons: (1) Plaintiffs failed to demonstrate non-compliance of the press with industry standards at the time of its manufacture; (2) The injury occurred in an area where it was unforeseeable for injuries to happen, as it was too distant from the ground; and (3) The modification of the lubrication system was not something Verson could have anticipated during manufacture, as there was no evidence indicating Verson's involvement in those changes.

The appellate review confirmed that the plaintiffs did not meet their burden of proof to show essential facts for their case, as mandated by the Celotex trilogy. Consequently, the district court's judgment was upheld.

In dissent, Circuit Judge Timbers argued that there was sufficient evidence for a jury to determine the foreseeability of the injury sustained by Allen, who claimed negligence and breach of implied warranty against Verson for a defectively designed press. Allen alleged that the design inadequately guarded a pinch point where his hand was injured. Under Michigan law, a manufacturer can be held liable for defective design if it creates an unreasonable risk of foreseeable injury. To establish a prima facie case, Allen needed to demonstrate the magnitude of foreseeable risks and the feasibility of alternative designs.

Negligence claims against product manufacturers can be dismissed via summary judgment if the claims are legally unenforceable or if public policy necessitates a particular outcome. The U.S. Supreme Court has supported summary judgment when plaintiffs fail to adequately demonstrate essential case elements. However, Michigan courts generally prefer that juries perform the risk-utility analysis to determine manufacturer liability for defective product designs, as juries are believed to better represent community standards of reasonableness.

In the case discussed, Allen argued that the press involved in his injury was defectively designed, referencing industry standards from the American National Standards Institute (ANSI). Specifically, he contended that the press did not meet the ANSI B15.1-1972 requirements, which specify guarding by enclosure or location. The court found that the opening where Allen's hand was crushed was not adequately guarded by location, as it was only 97 inches from the floor, whereas the standard required a minimum height of 108 inches.

Despite this, the court determined that the relevant standard was the ASA B15.1-1953, applicable when the press was manufactured, which allowed for unguarded moving parts to be 84 inches from the floor. Verson, the manufacturer, complied with this older standard. Nonetheless, compliance with industry standards does not absolve a manufacturer from potential negligence, as juries can still find liability based on the circumstances, as illustrated in previous case law. Judge Learned Hand emphasized that adherence to industry standards does not solely dictate reasonable prudence, as the industry may lag in adopting new safety measures.

The 1953 standard's relevance is reduced because it was outdated by at least 12 years when Verson manufactured the press. Evidence presented by Allen, including his deposition testimony, indicated he would not have placed his hand in the dangerous area if it had been properly guarded or warned. Testimony from Verson's expert, Donald Bernotus, confirmed that the pinch point posed a serious risk of injury and that guarding methods, such as shields, were known in the industry. This establishes that Verson was aware of the potential danger and may have had feasible options for safeguarding the area where Allen was injured.

The majority’s reliance on Verson's compliance with the outdated standard to dismiss Allen's claim was deemed excessive. The proximity of the oil reservoir refill point to the pinch point should have prompted Verson to implement additional safety measures. The court's conclusion that Allen's injury was unforeseeable due to its height above the floor was also contested. Allen provided enough evidence of negligent design for his claim to proceed to a jury trial, leading to a dissent against the majority's decision to dismiss the case.