Carruth v. Pittway Corp.
1994 WL 116967, 643 So. 2d 1340 (1994)
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Rule of Law:
A product warning may be legally inadequate if its presentation—due to factors like position, size, and coloring—is not calculated to attract a user's attention to critical safety information, thereby creating a question of fact for a jury. Circumstantial evidence can be sufficient to establish a causal link between an inadequate warning and an injury.
Facts:
- Coy Carruth purchased a 'First Alert' smoke detector manufactured by Pittway Corporation.
- The detector was packaged with a multi-page instructional pamphlet containing small, tightly-spaced print, and a colored diagram on the box purporting to show effective installation locations.
- Carruth testified that he did not read the pamphlet 'in depth' but got a 'general idea' of where to install the detector from the diagram on the box.
- On August 25, 1990, Carruth installed the smoke detector on a first-floor wall near the ceiling, in what was later alleged to be a 'dead air space' where smoke does not circulate well.
- Carruth tested the detector twice after installation; on one occasion, his son Brian, who was upstairs, heard the alarm and complained it was 'too loud.'
- On August 27, 1990, a fire started in the kitchen while seven family members were upstairs.
- All seven family members perished as a result of the fire.
Procedural Posture:
- Coy Carruth and other plaintiffs, as administrators of the estates of the deceased family members, filed wrongful death actions against Pittway Corporation in an Alabama trial court.
- The complaints alleged liability under the Alabama Extended Manufacturer's Liability Doctrine (AEMLD) and for negligent failure to adequately warn.
- Pittway Corporation filed a motion for summary judgment, arguing there was no genuine issue of material fact.
- The trial court granted summary judgment in favor of Pittway Corporation.
- The plaintiffs, with Coy Carruth as the appellant, appealed the trial court's grant of summary judgment to the Supreme Court of Alabama.
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Issue:
Does a manufacturer's warning create a genuine issue of material fact regarding its adequacy and causation when critical safety information is located within a lengthy, small-print pamphlet, while a prominent diagram on the product's box suggests a potentially unsafe installation location?
Opinions:
Majority - Justice Kennedy
Yes. A jury question exists as to whether a product warning is legally inadequate and whether that inadequacy caused the plaintiffs' injuries. Even if a warning's text is accurate, its presentation can render it inadequate if it is conveyed in a manner that is 'not calculated to attract the user's attention,' thereby discouraging a consumer from reading it. In this case, the combination of the pamphlet's small print and dense format, coupled with a potentially misleading diagram on the product's box, created substantial evidence that Pittway's warning about 'dead air spaces' was inadequate. Furthermore, circumstantial evidence—including expert testimony about the alarm's audibility, the victims' failure to attempt escape, and prior tests showing the alarm was audible upstairs—was sufficient to create a jury question on whether the failure to sound a timely alarm proximately caused the deaths.
Analysis:
This case significantly clarifies the 'failure to adequately warn' doctrine in products liability, emphasizing that the presentation and conspicuousness of a warning are as crucial as its substantive content. The court's ruling makes it more difficult for manufacturers to obtain summary judgment by merely showing that the necessary information was technically included in product literature. It establishes that if a warning is buried in fine print or contradicted by more prominent visuals, its adequacy becomes a question of fact for the jury. The decision also reinforces the principle that causation can be established through strong circumstantial evidence, even when direct evidence is unavailable because all witnesses have perished.
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