Mathews v. University Loft Co.
2006 N.J. Super. LEXIS 241, 903 A.2d 1120, 387 N.J. Super. 349 (2006)
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Rule of Law:
Under the New Jersey Products Liability Act, a manufacturer generally has no duty to warn against a product's danger if that danger is open and obvious to the ordinary consumer or user, even if the user is asleep and not in control of their behavior at the time of injury.
Facts:
- In the fall of 1999, Donald Mathews, a 21-year-old senior at Stockton State College, began sleeping in a new loft bed, manufactured by University Loft Company, which was six feet off the floor.
- Donald Mathews had never slept on a loft or bunk bed before.
- On October 11, 1999, Donald Mathews was asleep when his pager, located on a desk below the bed, went off, and his roommate yelled at him to turn it off.
- Startled by his roommate's yell, Donald Mathews fell off the bed, landing on his head and left shoulder, dislocating his shoulder.
- The loft bed manufactured by University Loft Company did not have any warning labels regarding the risk of falling.
- Donald Mathews testified that he had not considered falling dangerous and would have slept closer to the wall if a warning had made him aware of the hazard.
- George Widas, a consulting engineer and safety expert for Donald Mathews, testified that the six-foot-high bed posed a 'fall hazard' requiring a barrier or warning, and that the danger was not obvious to a sleeping occupant who cannot control their behavior.
- James Jannetidis, CEO of University Loft Company, testified that federal regulations governing warnings on such beds expressly exempted colleges and universities.
Procedural Posture:
- Donald Mathews filed a products liability action against University Loft Company alleging design, manufacturing, and warning defects.
- The trial court granted summary judgment dismissing Mathews' claims for design and manufacturing defects.
- The trial court denied summary judgment on Mathews' failure-to-warn claim, allowing that claim to proceed to trial.
- A jury subsequently found in favor of Donald Mathews on the failure-to-warn claim and awarded him $179,001, including prejudgment interest and costs.
- University Loft Company moved for a new trial and to vacate the judgment, which the trial court denied.
- University Loft Company appealed the July 23, 2004 'order of judgment' and the October 8, 2004 order denying post-trial motions to the Superior Court of New Jersey, Appellate Division, as the appellant against Donald Mathews as the respondent.
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Issue:
Does a manufacturer have a duty to warn a college student about the danger of falling from a six-foot-high loft bed when the risk of falling is considered open and obvious, given the modifications to product liability law under the New Jersey Products Liability Act?
Opinions:
Majority - Stern, P.J.A.D.
No, a manufacturer does not have a duty to warn a college student about the open and obvious danger of falling from a six-foot-high loft bed. The court concluded that the risk of falling from a bed, even when asleep, is an obvious and generally known danger to an ordinary person, particularly a college student. The court referenced the New Jersey Products Liability Act (PLA), N.J.S.A. 2A:58C-1 to -11, which governs product liability claims. While pre-PLA case law, such as Campos v. Firestone Tire & Rubber Co., treated the obviousness of a danger as merely one factor in determining a duty to warn, the PLA, specifically N.J.S.A. 2A:58C-3a(2), transformed "obvious danger" into an absolute defense for design defect claims (with an exception for industrial machinery). The court in Dewey v. R.J. Reynolds Tobacco Co. further clarified that this modification of the "obvious danger" standard has a direct impact on the common law governing the duty to warn, due to the similarity and interrelation between design defect and failure-to-warn causes of action. Both types of cases ultimately ask whether the manufacturer acted in a reasonably prudent manner. The court also cited the Restatement (Third) of Torts: Products Liability § 2, comment j, which states that sellers are generally not liable for failing to warn of obvious or generally known risks because such warnings often do not provide effective additional safety and may reduce the efficacy of warnings for non-obvious dangers. Considering the inherent characteristics of a loft bed and the ordinary knowledge common to college students, the court determined that the danger of falling from a six-foot-high bed is obvious. Even though Donald Mathews' expert argued that a person is not in control while asleep, the court found the risks so obvious that it could not conceive what a warning could have advised in addition to what was already apparent to protect a sleeping student from falling. Therefore, requiring such a warning would diminish the overall effectiveness of warnings.
Analysis:
This case significantly clarifies the application of the "open and obvious" danger doctrine in New Jersey product liability law, extending its role as an absolute defense beyond design defect claims to failure-to-warn claims for non-industrial products. By explicitly adopting the rationale of the Restatement (Third) of Torts, the court signals a more limited scope for manufacturer liability in situations where the danger is inherently discernible to the ordinary user. This ruling may impact future cases by making it more challenging for plaintiffs to succeed on failure-to-warn claims involving everyday products with commonly understood risks, reinforcing the idea that manufacturers are not required to warn against every conceivable misuse or incident when the hazard is self-evident.
