JAMES KNOX, APPELLANT,
v.
DELTA INTERNATIONAL MACHINERY CORPORATION, APPELLEE
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In this product liability case, the Florida District Court of Appeal affirmed summary judgment for Delta International Machinery Corp., holding that a jointer machine with a detachable safety guard was not unreasonably dangerous as a matter of law, even though the plaintiff lost two fingers when the guard was removed.
The court held that the jointer machine did not contain an unreasonably dangerous defect as a matter of law. A manufacturer has no duty to produce a fail-safe product so long as the product poses no unreasonable dangers for consumer use, and a manufacturer has no duty to warn consumers of obvious dangers such as operating machinery without its safety guard.
[1] A product is not unreasonably dangerous as a matter of law if it is reasonably safe for consumer use when used as intended, even if a safety feature can be removed.
[2] A manufacturer has no duty to produce a fail-safe product so long as the product poses no unreasonable dangers for consumer use.
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“a manufacturer is, as a matter of law, under no duty to produce a fail-safe product, so long as the product poses no unreasonable dangers for consumer use”
Establishes the core legal principle that manufacturers need not design fail-safe products, only reasonably safe ones for normal use.
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Join FLexlaw to unlock all legal intelligenceJames Knox was injured while using a jointer machine manufactured by Delta International Machinery Corp. The machine was designed with a safety guard,…
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PER CURIAM.
The final summary judgment entered in favor of the defendant Delta International Machinery Corp. in this product liability action is affirmed based on a holding that the jointer machine, which the plaintiff James Knox was using when he was injured, did not, as a matter of law, contain an unreasonably dangerous defect. The jointer machine was designed and manufactured with a safety guard, and was, without genuine dispute, reasonably safe for consumer use so long as the safety guard remained on the machine. The fact that the safety guard could be, and was in the instant case, detached from the machine, resulting in the loss of two of the plaintiff James Knox’s fingers, did not, as urged, render the machine unreasonably dangerous so as to permit a jury finding to that effect. This is so because a manufacturer is, as a matter of law, under no duty to produce a fail-safe product, so long as the product poses no unreasonable dangers for consumer use. Producing an otherwise safe jointer machine with a detachable safety guard poses no such unreasonable dangers. Nor was a warning required that the machine would be dangerous if the safety guard was removed; a manufacturer has no duty to warn consumers of such an obvious danger. See Husky Indus. v. Black, 434 So. 2d 988, 991 (Fla. 4th DCA 1983); Clark v. Boeing Co., 395 So. 2d 1226, 1229 (Fla. 3d DCA 1981); Royal v. Black & Decker Mfg. Co., 205 So. 2d 307, 310 (Fla. 3d DCA 1967), cert. denied, 211 So. 2d 214 (Fla.1968).
We have not overlooked the plaintiffs other arguments on this appeal, but find them unpersuasive. The final summary judgment under review is therefore, in all respects,
Affirmed.
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Authorities Cited
- Waltraud Mary Sexsmith Clark and Richard J. Clark v. The Boeing Co., 395 So. 2d 1226 (Fla. 3d DCA 1981)
- Husky Indus., Inc. v. Black, 434 So. 2d 988 (Fla. 4th DCA 1983)
- Lona Mae Royal v. The Black & Decker Mfg. Co., 205 So. 2d 307 (Fla. 3d DCA 1967)
- In re Est. of J. D. Miller, 211 So. 2d 214 (Fla. 1968)
- Reich v. Mazursky, 211 So. 2d 214 (Fla. 1968)