Knitz v. Minster Machine Co.
432 N.E.2d 814, 23 Ohio Op. 3d 403, 69 Ohio St. 2d 460 (1982)
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Rule of Law:
A product design is in a defective condition if it is more dangerous than an ordinary consumer would expect when used in an intended or reasonably foreseeable manner, or if the benefits of the challenged design do not outweigh the risk inherent in such design.
Facts:
- The appellant, a press operator, was injured while operating a punch press manufactured by the appellee.
- The press was equipped with a foot pedal control, which the appellant's employer had selected over the alternative two-hand surface button control.
- The press was also fitted with 'hold-back guards' designed to keep the operator's hands out of the die area when the ram descended.
- The appellant was not using the hold-back guards at the time of the incident.
- The appellant's injury occurred when she put her hands in the press and accidentally activated the ram by attempting to pull the foot switch towards her with her foot, not by intentionally trying to operate the machine.
Procedural Posture:
- The appellant filed a strict liability action against the appellee manufacturer for an alleged design defect.
- The appellee moved for summary judgment in the trial court.
- The trial court granted summary judgment in favor of the appellee.
- The appellant appealed to the Court of Appeals, which affirmed the trial court's judgment.
- The appellant then appealed to the Supreme Court of Ohio.
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Issue:
In a strict products liability claim for a design defect, is a product's design defective if it satisfies one of two alternative tests: the consumer-expectation test OR the risk-benefit test?
Opinions:
Majority - William B. Brown, J.
Yes. A product design is in a defective condition if it is proven to be defective under either the consumer-expectation test or the risk-benefit test. The court recognized that the consumer-expectation test, adopted in a previous case, is inadequate for situations where a consumer would not know what level of safety to expect, such as with complex industrial machinery. To address this, the court adopted an alternative risk-benefit test, where a design is defective if the jury determines that the risk of danger inherent in the design outweighs its benefits. Factors for this analysis include the likelihood and gravity of potential harm, and the mechanical and economic feasibility of an improved, safer design. Because the appellant presented expert testimony creating a genuine issue of fact as to whether the press's design was defective under this standard, summary judgment for the manufacturer was improper.
Dissenting - Holmes, J.
No. The manufacturer should not be held liable regardless of the standard applied because the press was not in a defective condition. The dissent argues that design defect claims should be based on negligence, not strict liability. Even under strict liability, the press was not defective because the manufacturer equipped it with safety devices (hold-back guards) that would have prevented the injury if used. The appellant was instructed on their proper use, and the accident would not have occurred had she followed instructions. The manufacturer should not be held absolutely liable for a user's carelessness when adequate safety measures are provided.
Dissenting - Krupansky, J.
No. The punch press was not defective as a matter of law. The dissent argues that the manufacturer complied with Ohio Industrial Commission regulations by providing acceptable guarding methods, including a two-hand tripping device and the hold-back guards. Compliance with such administrative safety standards should insulate a manufacturer from design defect liability as a matter of law. The dissent contends that the sole cause of the injury was the appellant's failure to wear the available safety device, not any defect in the machine itself.
Analysis:
This decision significantly expands design defect liability in Ohio by establishing a dual-pronged standard. By adding the risk-benefit test as an alternative to the consumer-expectation standard, the court makes it easier for plaintiffs to bring claims involving complex products where ordinary consumer expectations are ill-defined. This holding shifts the legal focus from the subjective expectations of the user to a more objective, hindsight-based evaluation of the design itself, considering the feasibility of safer alternatives. The ruling pressures manufacturers to incorporate feasible safety features, even for obvious dangers, if the risks of the existing design outweigh its benefits.
