Henderson v. Sunbeam Corp.

United States Court of Appeals for the Tenth Circuit

46 F.3d 1151 (10th Cir. 1995)

In a products-liability case, a plaintiff may prove causation with circumstantial evidence if the allegedly defective product has largely destroyed itself, making direct evidence of the precise defect unavailable.

Relevant Facts

Henderson (the plaintiff) owned an electric blanket manufactured by Sunbeam Corporation (the defendant). The plaintiff’s bedroom caught on fire, and caused substantial damage. The plaintiff brought a products-liability claim against the defendant, alleging that the electric blanket was the cause of the fire. Both of the plaintiff’s expert witnesses testified that the electric blanket was the cause of the fire, but did not agree on which particular aspect of the blanket’s electrical system caused the fire. One expert testified that a broken electrical connection caused the fire, but was unable to specify which particular connection due to the ruined state of the blanket after the fire. The defendant’s expert testified that the vibrator feature of the plaintiff’s bed caused the fire. The jury found in favor of the plaintiff and the district court denied the defendant’s post-trial motions. The defendant appealed.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 23, 2020

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Procedural History

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Citations

46 F.3d 1151 (10th Cir. 1995)