Parish v. Icon Health & Fitness, Inc.
719 N.W.2d 540, 2006 Iowa Sup. LEXIS 89, 2006 WL 2048995 (2006)
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Rule of Law:
Under product liability law, a product is defectively designed only if a plaintiff can prove a reasonable alternative design could have reduced foreseeable risks, unless the product is so manifestly unreasonable (low social utility, high danger) that liability attaches without an alternative design. A product is defectively warned if foreseeable risks could have been reduced by reasonable instructions or warnings.
Facts:
- In June 1999, Delbert Parish and Shelley Tatro purchased a Jumpking fourteen-foot trampoline for use in their backyard.
- After Delbert Parish nearly fell while attempting a somersault, he and Shelley Tatro purchased a 'fun ring' (a netlike enclosure) for the trampoline.
- On September 11, 1999, James Parish, while visiting his brother, attempted a back somersault on the trampoline.
- James Parish landed on his head while attempting the somersault.
- As a result of landing on his head, James Parish was rendered a quadriplegic.
Procedural Posture:
- In August 2001, James Parish filed suit in district court against Jumpking, Inc., alleging theories of defective design and negligence in failing to warn.
- Jumpking, Inc. moved for summary judgment in the district court.
- The district court granted Jumpking, Inc.'s motion for summary judgment on all claims.
- James Parish appealed the district court's grant of summary judgment.
- On appeal, James Parish (appellant) argued that the district court erred because genuine issues of material fact existed regarding his design-defect claim and the adequacy of Jumpking's (appellee) warnings.
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Issue:
1. Does the absence of a reasonable alternative design preclude a finding of design defect for a common and widely distributed product like a trampoline, even if the plaintiff argues the design is 'manifestly unreasonable' due to inherent danger? 2. Were the warnings provided by Jumpking, Inc. on its trampoline and fun ring inadequate to warn users of the foreseeable risks of harm, specifically attempting somersaults?
Opinions:
Majority - LARSON, Justice
1. No, the absence of a reasonable alternative design generally precludes a finding of design defect for a common and widely distributed product like a trampoline, as it does not meet the narrow criteria for the "manifestly unreasonable" exception. The court, adopting Restatement (Third) of Torts: Products Liability § 2(b), holds that a plaintiff must ordinarily show a "reasonable alternative design" that would have reduced foreseeable harm at a reasonable cost. While § 2(b) comment e recognizes an exception for designs that are "manifestly unreasonable" due to low social utility and high danger, the court emphasized this exception is to be "sparingly applied," typically reserved for "extremely dangerous products with very low social utility" that should not be marketed at all (e.g., an exploding cigar). The court found that trampolines, being common and widely distributed products with recognized benefits (exercise, therapy) and a relatively low injury rate compared to other recreational activities, do not fall under this exception. For such products, the court concluded that legislative or administrative action is more appropriate than judicial intervention to consider their commercial distribution. Therefore, James Parish failed to generate a genuine issue of material fact regarding a design defect under the "manifestly unreasonable" exception. 2. No, the warnings provided by Jumpking, Inc. were not inadequate because they explicitly cautioned against the specific conduct that caused James Parish's injury. Applying Restatement § 2(c), which addresses inadequate warnings, the court found that Jumpking provided numerous warnings that exceeded American Society for Testing and Material (ASTM) requirements. These warnings were permanently affixed to the trampoline pad and legs, sewn onto the mat, and included in placards and owner's manuals for both the trampoline and the fun ring. Crucially, the warnings explicitly advised, "Do not do somersaults (flips)" and "Do not land on head or neck. Paralysis or death can result." Since these warnings directly addressed the specific conduct (attempting somersaults) that led to James Parish's injury, the court concluded that a reasonable fact finder could not find them inadequate. The court also noted that users have a responsibility for proper product use, and excessive safety requirements are not beneficial to society.
Analysis:
This case significantly clarifies the application of the Restatement (Third) of Torts: Products Liability in Iowa, reinforcing the high bar for proving design defects. It establishes that the "manifestly unreasonable" exception to the reasonable alternative design requirement is extremely narrow, reserved for products with truly egregious danger and minimal social utility, effectively making it inapplicable to common recreational products like trampolines despite inherent risks. The ruling also underscores the importance of comprehensive, explicit warnings, demonstrating that manufacturers can effectively mitigate liability by clearly communicating foreseeable risks, especially when those warnings directly address the specific harmful conduct. Future product liability plaintiffs will face considerable difficulty without a viable alternative design or if the product does not genuinely represent an "antisocial" item with virtually no redeeming value.
