Farkas v. Addition Manufacturing Technologies, LLC, No. 19-1068 (8th Cir. 2020)
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After plaintiff's fingers were severely injured by a machine that uses a hydraulic clamp to crimp metal tubes, he filed suit against Addition, the machine designer's successor. The Eighth Circuit affirmed the district court's grant of summary judgment for Addition, holding that plaintiff failed to provide facts showing that the machine was inherently dangerous or improperly guarded at the time it entered the stream of commerce. Therefore, the court concluded that plaintiff failed to establish a material issue of fact as to his strict liability claims.
In regard to his products liability claims, the court held that plaintiff failed to offer evidence that the danger of a tube forming machine to the user's hand was anything but "open, obvious, and apparent." Therefore, the defect was not latent under Missouri case law, and thus not a material issue of fact regarding his negligence claim.
Court Description: [Smith, Author, with Beam and Erickson, Circuit Judges] Civil case - Products liability. The district court did not err in granting defendant's motion for summary judgment on plaintiff's products liability claim as plaintiff failed to show the hydraulic press in question was defective or dangerous at the time of sale in 1992; with respect to plaintiff's claim for negligent product liability, plaintiff failed to show defendant owed him a duty under Missouri law as the defect was not latent because the danger of operating the press without a guard was open, obvious and apparent.
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