McCormack v. Hankscraft Company

Supreme Court of Minnesota
278 Minn. 322, 154 N.W.2d 488 (1967)

ELI5:

Rule of Law:

A manufacturer is liable for injuries caused by its product when it fails to provide adequate warnings about non-obvious dangers, adopts an unsafe design for which there are feasible alternatives, or breaches an express warranty of safety.

Facts:

In 1957, Donald McCormack purchased a Hankscraft electric steam vaporizer for his infant daughter, Andrea, relying on an instruction booklet representing the product as 'safe' and 'practically foolproof' for unattended use.
In 1960, after the first unit stopped working, Andrea's mother purchased a similar Hankscraft vaporizer, relying on the company's previous representations of safety.
The vaporizer's design consisted of a glass jar filled with water and a plastic cap/heating unit that rested loosely on top without being screwed or fastened down.
During operation, the water in the glass jar reached scalding temperatures of up to 211°F, a fact that was not obvious to a user and was not disclosed in the instructions.
On November 20, 1960, Andrea, then three years old, got out of bed during the night and tipped over the vaporizer.
The unsecured top separated from the jar, causing the scalding hot water to gush out and inflict third-degree burns on over 30% of Andrea's body.
Hankscraft's officers knew the water became dangerously hot, that the unsecured cap posed a hazard, and that at least 10 to 12 other children had been burned in a similar manner prior to Andrea's injury.

Procedural Posture:

Andrea McCormack, through her father, sued Hankscraft Company, Inc. in a Minnesota district court (trial court) for damages.
The case was tried before a jury, which returned a verdict in favor of McCormack for $150,000.
Hankscraft filed a post-trial motion for judgment notwithstanding the verdict (n.o.v.) and, alternatively, for a new trial.
The trial court granted Hankscraft's motion, setting aside the jury's verdict and ordering judgment for Hankscraft.
McCormack appealed the trial court's order to the Supreme Court of Minnesota.

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Issue:

Is a manufacturer liable for negligence and breach of express warranty when its steam vaporizer, marketed as 'safe' for unattended use in a child's room, has an unsecured top that allows scalding water to spill out when tipped over, causing severe injury to a child?

Opinions:

Majority - Rogosheske, Justice.

Yes. A manufacturer is liable under theories of negligence and breach of express warranty for injuries caused by its defectively designed and inadequately labeled product. The court found sufficient evidence for the jury's verdict based on three grounds. First, Hankscraft was negligent for failing to warn users that the water in the reservoir became scalding hot, a danger that was not obvious and was concealed by representations of safety. Second, Hankscraft was negligent in adopting an unsafe design; the unsecured top created a foreseeable risk of serious injury to children, and expert testimony showed that a simple, inexpensive, and practical alternative design, such as a screw-on cap, would have prevented the water from spilling. Third, Hankscraft's statements in its booklet that the vaporizer was 'safe' and 'practically foolproof,' especially when pictured near a baby's crib, constituted an express warranty which was breached when the product proved unsafe for its intended use and caused Andrea's injuries.

Analysis:

This case is significant for its comprehensive application of product liability theories, including negligent design, failure to warn, and breach of express warranty. More importantly, the court explicitly signals its adoption of the emerging doctrine of strict liability in tort, as articulated in the Restatement (Second) of Torts § 402A. By stating its intent to move past contractual defenses like privity and notice in personal injury cases, the court shifted the legal framework toward a policy-driven approach that places the cost of injuries from defective products on the manufacturer, who is in the best position to prevent the harm and distribute the cost.

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