124 N.E.3d 616
Ind.2019Background
- PACCAR manufactured a sleeper-cab "glider kit" (cab and frame) that a purchaser (W&W) outfitted with an engine, transmission, and exhaust to create an operable over‑the‑road semi.
- The completed vehicle had a known ~40‑foot blind spot directly behind the truck; PACCAR did not include certain safety features (rear window, backup alarm, backup camera, backup flashers) as standard unless specifically ordered.
- While a W&W driver was reversing the truck, he struck and killed construction foreman Rickey Brewer; Brewer’s widow sued PACCAR under the Indiana Product Liability Act (IPLA) for defective design and failure to warn.
- PACCAR moved for summary judgment arguing it owed no duty, as a matter of law, to include the safety features because it made only a component part and any duty rested with the final manufacturer; PACCAR submitted affidavits saying options were available.
- The trial court granted summary judgment for PACCAR; the Court of Appeals reversed; the Indiana Supreme Court granted transfer and addressed when a component‑part manufacturer owes a duty to include safety features.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether PACCAR, as a component‑part manufacturer, owed a duty as a matter of law to include safety features on the glider kit | Brewer: the glider kit had one foreseeable use (becoming an over‑the‑road semi) and was defective when conveyed because it lacked safety features | PACCAR: no duty as a matter of law because it manufactured only a component; any duty to add safety features rested with the final manufacturer (W&W) | A component maker with one reasonably foreseeable use is not relieved of duty as a matter of law unless it shows (1) it offered the features and the final manufacturer declined them, or (2) the integrated product can be used safely without the features; PACCAR proved neither, so summary judgment reversed |
| Whether optional‑feature evidence (manufacturer offered options that were declined) can absolve a component maker of duty | Brewer: disputed whether options were offered; absence of such proof leaves duty issue factual | PACCAR: engineer affidavits said options existed and were not chosen by W&W | Held: If the final manufacturer was actually offered and declined options, the component maker can have no duty—but PACCAR failed to prove W&W was offered and rejected the options (factual dispute) |
| Whether the component can be safe without the alleged features (second ground to negate duty) | Brewer: designated expert opined the design was defective without the safety features | PACCAR: cited evidence (e.g., spotter practice, MSHA guidance on alarms) arguing safe use without certain features in some contexts | Held: PACCAR did not establish as a matter of law that the integrated glider kit could be used safely without the alleged features; factual dispute remains |
| Applicability of the sophisticated‑user defense to design‑defect claims | Brewer: not dispositive on summary judgment; factual question | PACCAR: asserted W&W is a sophisticated purchaser/final manufacturer, implying the defense | Held: Sophisticated‑user defense applies to design‑defect claims but is typically for the trier of fact; not dispositive on summary judgment here |
Key Cases Cited
- Shanks v. A.F.E. Indus., 416 N.E.2d 833 (Ind. 1981) (component maker had no duty to add safety features where end product could take many configurations and maker could not know specific contexts)
- Del Signore v. Asphalt Drum Mixers, 182 F. Supp. 2d 730 (N.D. Ind. 2002) (applying Indiana law; component manufacturer relieved of duty where owner could configure complex in multiple ways)
- Fleck v. KDI Sylvan Pools, 981 F.2d 107 (3d Cir. 1992) (component maker of a pool liner could foresee single use and may bear duty to include safety features/warnings)
- Anderson v. P.A. Radocy & Sons, 865 F. Supp. 522 (N.D. Ind. 1994) (component maker not liable for optional insulating bucket after final purchaser knowingly rejected option)
- TRW Vehicle Safety Sys. v. Moore, 936 N.E.2d 201 (Ind. 2010) (both component and final manufacturers are "manufacturers" under the IPLA)