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Campos v. Crown Equipment Corp.
Citation: 35 F. App'x 31Docket: Docket No. 01-9143
Court: Court of Appeals for the Second Circuit; May 28, 2002; Federal Appellate Court
The judgment of the District Court for the Southern District of New York is affirmed in the case of Euclides Campos against Crown Equipment Corporation and Crown Credit Company. Campos sustained serious foot injuries from a forklift accident on December 7, 1999, involving a forklift manufactured by Crown and leased to his employer, Data Path Technologies, Inc. Campos claimed the forklift was defective for lacking optional safety features like a backup alarm and warning lights. The District Court ruled that Campos did not establish a prima facie case of defectiveness, citing the precedent set in Scarangella v. Thomas Built Buses, Inc. A defectively designed product is one that is unreasonably dangerous and not reasonably contemplated by the consumer at the time of sale. The Scarangella case determined that a manufacturer is not liable for the absence of optional safety features if the buyer is knowledgeable about the product and aware of the available safety options. In this case, Data Path had extensive experience with forklifts and had previously installed a backup alarm on another model, indicating they were knowledgeable consumers. Campos failed to demonstrate that forklifts without the safety equipment were inherently dangerous in all circumstances, as normal operations without pedestrians could exist. Furthermore, Data Path was better positioned than the Crown defendants to assess the risks and benefits associated with safety features, considering their operational context. As the Crown defendants satisfied all three criteria from Scarangella, they cannot be held liable for a defectively designed forklift. The District Court's ruling is thus upheld, affirming the absence of liability on the part of the Crown defendants.