Richter v. Limax International

Dearmedia Richter (plaintiff) bought a mini-trampoline from Limax International (defendant) for jogging exercise, and developed stress fractures in both ankles. She sued for strict liability and negligent failure to warn. The box carried a sticker limiting use to exercise, not acrobatics. At trial, Richter's expert testified simple tests would have shown that repetitive jogging on the trampoline stressed the feet and legs; Limax admitted it ran no such tests but said this was the first complaint of its kind. The jury found the design itself wasn't defective but held Limax liable for failing to warn, awarding over $450,000 reduced for Richter's own 38% fault. The district court granted Limax judgment as a matter of law, ruling Limax had no duty to warn of dangers only discoverable through testing it never performed. Richter appealed.