Halliday v. Sturm, Ruger & Co.

Three-year-old Jordan Garris fatally shot himself after finding his father's handgun, which had come with a declined safety course, a safety manual, and a lock box that the father had ignored, leaving the loaded gun under his mattress. Jordan's mother, Halliday (plaintiff), sued the gun's manufacturer, Sturm, Ruger & Co. (defendant), for design defect, arguing the gun lacked a feasible childproof grip safety and citing statistics on children killed by handguns to argue such misuse was foreseeable. Halliday urged the court to apply a risk-utility analysis, under which the gun would fail because the risk of omitting child safety features outweighed the utility of leaving them out; the trial court instead applied the consumer expectations test and granted summary judgment for Sturm Ruger, and the appellate court affirmed.