Linden v. CNH America, LLC
United States Court of Appeals for the Eighth Circuit
673 F.3d 829 (2012)
Thomas Linden Jr. (plaintiff) suffered severe injuries when ejected from a bulldozer cab during a rollover accident, and sued the bulldozer manufacturer, CNH America, LLC, and the seatbelt manufacturer, IMMI (defendants), for products liability, claiming three manufacturing defects in the seatbelt buckle: insufficient UV-resistant material in the casing, lack of strengthening polycarbonate, and a housing that fit the ejector holder too loosely. The court dismissed claims against IMMI as time-barred and granted CNH a directed verdict on Linden's manufacturing-defect claims; Linden appealed.
Whether a manufacturing defect requires showing that a product departed from its intended design.