Matthews v. Remington Arms Co., Inc.
2011 U.S. App. LEXIS 10036, 2000 WL 35894124, 641 F.3d 635 (2011)
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Rule of Law:
Under the Louisiana Products Liability Act (LPLA), a manufacturer is not liable for damages that arise from a product's use if that 'use' includes a third party's failure to reinstall a critical component after disassembly, as such a circumstance is not a 'reasonably anticipated use' the manufacturer should expect.
Facts:
- Remington Arms Company, Inc. manufactured the Model 710 rifle with a two-piece bolt assembly, where the bolt head is attached to the bolt body with a bolt-assembly pin.
- The owner's manual for the rifle instructs users on how to disassemble the bolt assembly, which includes removing the bolt-assembly pin for cleaning, and how to reassemble it.
- The rifle in question was manufactured in 2001 and passed through several owners before being purchased by Margaret Minchew in 2006.
- Minchew loaned the rifle to her daughter and Nicholas Glass, who installed a new scope on it.
- In October 2006, Jerry Matthews borrowed the rifle to 'sight' the new scope.
- Matthews loaded the rifle, which misfired on the first attempt.
- Matthews reloaded the rifle and pulled the trigger a second time, causing an uncontained explosion that sent parts of the bolt assembly into his head, resulting in serious injuries, including the loss of an eye.
- It was later determined that the explosion occurred because the bolt-assembly pin was missing, which prevented the bolt head from locking with the barrel, causing the rifle to fire while 'out of battery'.
Procedural Posture:
- Jerry Matthews filed a lawsuit against Remington Arms Company, Inc. in the U.S. District Court for the Western District of Louisiana under the Louisiana Products Liability Act.
- The case was decided in a bench trial (a trial by a judge without a jury).
- The district court entered a judgment in favor of Remington, finding that Matthews's injury did not arise from a 'reasonably anticipated use' of the rifle.
- Matthews filed a motion for a new trial, which the district court denied.
- Matthews, as the appellant, appealed the district court's judgment to the U.S. Court of Appeals for the Fifth Circuit.
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Issue:
Under the Louisiana Products Liability Act, does a plaintiff's injury arise from a 'reasonably anticipated use' when it results from firing a rifle after someone has removed and failed to reinstall a critical component like the bolt-assembly pin?
Opinions:
Majority - Barksdale, J.
No. A plaintiff's injury does not arise from a 'reasonably anticipated use' when it results from firing a rifle with a missing critical component that was removed and not reinstalled by someone. The Louisiana Products Liability Act's definition of 'use' is broad and includes not only the claimant's final action (firing the rifle) but also the preceding handling of the product by the 'claimant or another person or entity.' The court found that Remington could not have reasonably anticipated that a user would disassemble the rifle and fail to reinstall an essential component like the bolt-assembly pin. A manufacturer is entitled to expect an ordinary user to reassemble a product with all its parts. With nearly 500,000 rifles sold and no prior reports of this specific issue, Remington had no reason to expect such misuse, which is distinct from a merely 'foreseeable' misuse under older, pre-LPLA standards.
Dissenting - Dennis, J.
Yes. The injury did arise from a reasonably anticipated use. The majority misinterprets the LPLA by focusing on the actions of an unknown third party rather than the claimant's own actions. Matthews's 'use' of the rifle was to fire it at a target, which is the core, intended purpose of the product and therefore a 'reasonably anticipated use.' The LPLA's 'another person or entity' language is intended to protect innocent bystanders, not to create an additional hurdle for a claimant who was using the product as intended. The case should have proceeded to the merits to determine if the rifle was unreasonably dangerous in design or lacked an adequate warning about the risk of explosion if the pin was missing.
Analysis:
This decision significantly narrows manufacturer liability under the Louisiana Products Liability Act by adopting a broad interpretation of 'use' that includes prior handling and misassembly by third parties. It solidifies the distinction between the LPLA's 'reasonably anticipated use' standard and the older, more plaintiff-friendly 'reasonably foreseeable misuse' standard. The ruling makes it more difficult for plaintiffs to recover if their injury stems from a product that was altered or improperly reassembled, even if the plaintiff was unaware of the defect. It places a higher burden on plaintiffs to show that the specific manner of misuse, not just the general use, was something the manufacturer should have reasonably expected.
