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Manley-Deboer Lumber Co. v. Georgia-Pacific Corp.

Citations: 897 So. 2d 528; 2005 Fla. App. LEXIS 2451; 2005 WL 475538Docket: No. 3D04-2362

Court: District Court of Appeal of Florida; March 1, 2005; Florida; State Appellate Court

Narrative Opinion Summary

In this product liability litigation, the plaintiff sustained injuries from a metal object embedded in lumber while sawing. The lumber was purchased from a retailer, Manley-Deboer Lumber Company, which sourced it from several suppliers, including Georgia-Pacific Corporation and Georgia-Pacific Products, Inc. The plaintiff initiated a lawsuit against the retailer and multiple suppliers, alleging their responsibility for the defective lumber. However, the plaintiff failed to produce evidence to identify which supplier provided the specific piece of lumber involved. The trial court granted summary judgment in favor of the suppliers, ruling that the plaintiff could not establish a causal link between the lumber and any individual supplier without resorting to impermissible inferences. The court underscored the necessity for the plaintiff to prove that the product causing injury was manufactured or sold by the defendant, adhering to established case law. The decision was upheld as there was no genuine issue of material fact and the suppliers were entitled to judgment as a matter of law. The outcome favored the suppliers, affirming the dismissal of claims against them in the absence of concrete evidence.

Legal Issues Addressed

Impermissible Inferences in Establishing Supplier Liability

Application: The court found that the plaintiff could not establish liability against the suppliers without resorting to impermissible inferences due to lack of specific evidence linking the lumber to a particular supplier.

Reasoning: The court found that establishing liability against the suppliers required impermissible inferences, as the plaintiff could not definitively connect the injury-causing lumber to any specific supplier.

Product Liability and Identification of Defendant's Product

Application: The court applied the principle that a plaintiff must provide evidence linking the injury-causing product to a specific defendant in order to establish liability.

Reasoning: The ruling affirmed the principle that a plaintiff must prove that the product causing injury was manufactured or sold by the defendant, as established in previous case law.

Summary Judgment Standards

Application: The court determined that summary judgment was appropriate because the plaintiff failed to present a genuine issue of material fact regarding the identity of the supplier responsible for the defective product.

Reasoning: Summary judgment was deemed appropriate because there was no genuine issue of material fact, and the movant was entitled to judgment as a matter of law.