Metzgar v. Playskool Inc.
United States Court of Appeals for the Third Circuit
30 F.3d 459 (1994)
Ronald Metzgar's (plaintiff) 15-month-old son choked to death on a Playskool (defendant) building block that met federal consumer product safety size and shape standards, though the box (labeled for ages 1.5 to 5) carried no choking-hazard warning; Playskool noted no prior choking complaints about the block in 20 years, but Metzgar's expert testified that 11 children died from choking on small toys or toy parts in 1988 alone. The district court's risk-utility analysis found the choking risk too small to be unreasonable and granted Playskool summary judgment; Metzgar appealed.
Whether, in determining whether a manufacturer is liable for a design defect, a court must conduct a risk-utility analysis to balance the benefits of the product against the risk of the product's potential harm.