McKenzie v. S K Hand Tool Corp.
Illinois Appellate Court
650 N.E.2d 612 (1995)
Ronnie McKenzie (plaintiff) was injured when a ratchet wrench manufactured by S K Hand Tool Corporation (SKHT) (defendant) came apart while he used it to loosen an engine bolt, causing him to fall. McKenzie's manufacturing-defect claim relied on expert testimony that the wrench's snap-ring groove exceeded specification tolerances and was improperly tapered, along with coworker testimony that the wrench had never been disassembled since purchase; the trial court refused to submit this design-specification evidence to the jury, the jury returned a verdict for SKHT, and McKenzie appealed.
Whether a plaintiff may prove the existence of a manufacturing defect by showing proof of a deviation from design specifications.