Jones v. Ryobi, Ltd.
U.S. Court of Appeals, Eighth Circuit
37 F.3d 423 (1994)
Jones (plaintiff) was injured adjusting the eject wheels on a printing press manufactured by Ryobi and distributed by A.B. Dick (defendants). At the time of sale, the press had a safety guard and interlock switch preventing operators from reaching moving parts while the press ran, but Jones's employer removed both after purchase — a modification common in the industry that allowed adjusting the wheels without stopping the machine. Jones's hand was crushed while adjusting the wheels on the running, unguarded press, and she sued for strict liability based on defective design. The district court granted judgment as a matter of law for the defendants based on the danger being open and obvious, and Jones appealed.
Whether a manufacturer or seller may be held liable for injuries caused by a third party's unsafe modification to a product, where the product was safe at the time it was originally sold.