McCormack v. Hankscraft Co.
Minnesota Supreme Court
154 N.W.2d 488 (1967)
Donald McCormack (plaintiff) bought a Hankscraft (defendant) steam vaporizer to use as a humidifier for his eight-month-old daughter, Andrea. The unit was placed near Andrea's bed and left running overnight; when Andrea got up and knocked it over, scalding water at 211 degrees spilled on her, burning over 30 percent of her body and causing permanent injuries requiring skin grafts. The instruction manual, which the McCormacks had read fully, called the unit "safe" and "practically foolproof" but never disclosed the scalding temperature the water reached or warned of the risk if the unit tipped over. A jury found Hankscraft liable, but the trial judge granted judgment notwithstanding the verdict and a conditional new trial; the McCormacks appealed.
Whether a manufacturer has a duty to use reasonable care in designing a product so that those using it for its intended purpose are protected from an unreasonable risk of foreseeable harm.