Warner Fruehauf Trailer Co. v. Boston
District of Columbia Court of Appeals
654 A.2d 1272 (1995)
Boston (plaintiff), a utility supervisor, was struck by a 1,050-pound liftgate platform that suddenly fell free from its closed position while he approached to attach safety chains, and evidence showed similar liftgates had experienced comparable free-fall failures in over half of tested units, with the manufacturer's own post-accident testing reproducing the mechanical failure repeatedly during normal operation; Boston's expert testified the design was unreasonably dangerous absent a fail-safe backup and that feasible, cost-effective alternative designs existed. The trial court directed a verdict for Boston on liability, a jury awarded $550,000 in damages, and manufacturer Warner (defendant) appealed.
Whether a manufacturer is strictly liable for defective design, in a risk-utility jurisdiction, if the plaintiff proves the likelihood and magnitude of injury from the product exceeds the cost of a reasonable alternative design.