Joseph Knott v. AMFEC, Inc., No. 11-2508 (8th Cir. 2012)
Annotate this CaseCourt Description: Civil case - Products liability. Under Minnesota law, a manufacturer's duty to warn consumers of foreseeable dangers is relieved when the danger the product poses is open and obvious, as it was here.
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United States Court of Appeals FOR THE EIGHTH CIRCUIT ___________ No. 11-2508 ___________ Joseph Knott, Appellant, v. AMFEC, Inc., Appellee. * * * * Appeal from the United States * District Court for the * District of Minnesota. * * [UNPUBLISHED] * ___________ Submitted: February 14, 2012 Filed: June 28, 2012 ___________ Before GRUENDER, BENTON, and SHEPHERD, Circuit Judges. ___________ PER CURIAM. A 3,000-pound-capacity meat blender/mixer severed part of Joseph Knott s hand when, while preparing to wash the blender from atop a platform with the blender running and its safety grate open, Knott slipped and his arm entered the blender. Knott brought suit against AMFEC, Inc., which purchased the assets of the company that manufactured the blender, arguing that AMFEC had a post-sale duty to warn of the dangers involved in cleaning the blender in the manner attempted by Knott. The district court1 granted summary judgment to AMFEC on the ground that the danger posed by cleaning the blender with the safety grate open and the blender in operation was obvious and that under Minnesota law manufacturers do not have a duty to warn of a foreseeable danger if the danger would be obvious to anyone using the product. Knott v. AMFEC, Inc., No. 09-CV-1098, 2010 WL 4116602, at *5 (D. Minn. Oct. 18, 2010); see also Gamradt v. Fed. Labs., Inc., 380 F.3d 416, 419 (8th Cir. 2004) ( Under Minnesota law, a manufacturer has a duty to warn consumers of reasonably foreseeable dangers. This duty is relieved, however, when the danger the product poses is open and obvious. (internal citations omitted)). Knott now appeals, and, after de novo review, see id., we affirm for the reasons stated in the district court s well-reasoned opinion. See 8th Cir. R. 47B. ______________________________ 1 The Honorable Patrick J. Schiltz, United States District Judge for the District of Minnesota. -2-
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