Jonathan Edwards v. Skylift, Inc., No. 21-2984 (8th Cir. 2022)Annotate this Case
After Plaintiff was injured by a machine that Skylift, Inc., manufactured and sold, he sued Skylift claiming that the machine was defective and unreasonably dangerous and that Skylift negligently designed it. The district court rejected these claims and granted summary judgment to Skylift.
The Eighth Circuit affirmed the district court’s ruling granting summary judgment to Skylift. The court held that the product was not unreasonably dangerous, i.e., "dangerous to an extent beyond that which" was actually contemplated by the machine's users. The court explained that Plaintiff does little to confront this glaring deficiency in his claim, focusing instead on the feasibility of adding certain features to the machine that he says would have prevented the accident.
Further, the court explained that Arkansas recognizes that a plaintiff may assert both strict liability and negligence claims in a product-liability action. Here, Plaintiff does not convincingly argue that the machine fell short of contemporary industry standards; in fact, Plaintiff’s expert may well have admitted they satisfied those standards. In sum, the court found nothing that calls into question the lower court’s determinations that the machine was not unreasonably dangerous under Arkansas law or that Skylift did not negligently design it.
Court Description: [Arnold, Author, with Loken and Kelly, Circuit Judges] Civil case - Torts. In action alleging a derrick digger manufactured and sold by defendant was defective, unreasonably dangerous and negligently designed because an override switch allowed the digger to be operated without the deployment of stabilizing outriggers, the district court did not err in granting defendant summary judgment because plaintiff had not produced sufficient evidence to support a finding that the derrick digger was unreasonably dangerous as Arkansas defines that phrase; as a result, the court need not decide whether the machine's design was defective; with respect to the claim of negligent design, no jury could have found that the machine was negligently designed, and the district court did not err in granting defendant summary judgment on this claim.