Parks v. Ariens Co., No. 15-2664 (8th Cir. 2016)
Annotate this CaseTimothy Parks died from asphyxiation after the Gravely Promaster 152Z riding mower he was operating on his property fell off the edge of an embankment and rolled over on top of him. Plaintiff, Timothy's wife, filed suit alleging that the manufacturer of the 152Z, Ariens, was negligent for failing to equip the machine with a rollover protection system (ROPS). The district court granted summary judgment against plaintiff. The optional equipment doctrine holds that a manufacturer is, under certain circumstances, not negligent if a purchaser fails to buy optional safety equipment that would have prevented the accident. Although the Iowa Supreme Court has not yet considered the optional equipment doctrine, policy reasons and the popularity of the optional equipment doctrine lead the court to conclude that the Iowa court would adopt it. Therefore, in this case, the court concluded that Ariens fulfilled any duty it had to Timothy when it provided the ROPS as an optional feature for the 152Z mower and ensured that he had the information necessary to make an informed choice. Accordingly, the court affirmed the judgment.
Court Description: Kelly, Author, with Shepherd and Beam, Circuit Judges] Civil case - Products liability. In action alleging defendant was negligent in failing to equip the riding mower which killed plaintiff's husband with a rollover protection system, the district court did not err in granting summary judgment for defendant based on its conclusion that it had satisfied any duty it owed the deceased by offering a rollover protection system as an optional feature and by ensuring he had the information necessary to make an informed choice at the time of purchase; while Iowa courts have not considered the optional equipment doctrine, policy reasons and its popularity lead the court to conclude the Iowa Supreme Court would adopt it.
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