Davis v. Little Giant Ladder Systems, LLC, 2:19-cv-00780

Plaintiff Craig Davis fell from a Little Giant Velocity ladder (approx. 15 feet) while in an extension configuration and suffered serious injuries; he alleges the ladder telescoped after a Rock Lock failed.
The disputed failure mode is a "false lock" (barrel pin partially seated on a swage ring so the lock appears engaged but is not fully inserted), distinct from "unintentional disengagement" tied to a prior recall.
The ladder at issue contained Rock Lock 2.1 components (originally manufactured with 2.0 then swapped pre-sale); Little Giant previously issued a recall for a separate disengagement issue.
Plaintiffs assert design and manufacturing defect claims (negligence and strict liability), failure to warn, breach of implied warranty, and loss of consortium; plaintiffs also seek punitive damages.
Court considered multiple Daubert motions and Little Giant’s motion for summary judgment; most expert testimony was admitted with a limited exclusion, Count 3 (failure to warn) was dismissed with prejudice, punitive damages were stricken, and the remainder of claims survive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of experts (Poczynok, Knox, Russell)	Poczynok’s false-lock opinions are reliable; Knox and Russell unreliable/methodologically flawed	Criticisms go to weight; experts measured and relied on testing/standards	Court largely admitted experts. Poczynok allowed except he may not opine about Craig’s personal perception (human-factors) during the incident; Knox and Russell admitted.
Failure-to-warn (Count 3)	Warnings failed to disclose risk of false locking and were inadequate to prevent injury	Warnings were clear, accurate, and unambiguous; plaintiff read/understood and complied	Count 3 dismissed with prejudice (warnings adequate and, alternatively, plaintiff cannot show proximate causation; expert needed but not provided).
Punitive damages	Little Giant knowingly risked safety (cost-driven design choices, warranty reports, inventory decisions)	Company complied with industry/ANSI testing, investigated, and lacked knowledge of a false-lock safety hazard	Punitive damages stricken (plaintiff did not meet clear-and-convincing standard for gross negligence or intentional misconduct).
Design/manufacturing defect and liability claims	False lock caused the fall; experts support defect theories	Defendant argues testing, measurements, and alternative explanations undermine defect proof	Summary judgment denied as to these surviving claims; genuine factual disputes remain for jury.

Daubert v. Merrell Dow Pharms., 509 U.S. 579 (1993) (trial-court gatekeeping standard for expert testimony)
Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999) (Daubert principles apply to non-scientific expert testimony)
United States v. Frazier, 387 F.3d 1244 (11th Cir. 2004) (three-part Daubert analysis in the Eleventh Circuit)
Moore v. Intuitive Surgical, Inc., 995 F.3d 839 (11th Cir. 2021) (distinguishing reliability, qualifications, and helpfulness inquiries)
McCorvey v. Baxter Healthcare Corp., 298 F.3d 1253 (11th Cir. 2002) (factors for assessing expert reliability)
Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary-judgment standard regarding genuine disputes of material fact)
Eghnayem v. Boston Sci. Corp., 873 F.3d 1304 (11th Cir. 2017) (warning-adequacy usually a jury question but can be decided as a matter of law when warnings are clear)
Farias v. Mr. Heater, Inc., 684 F.3d 1231 (11th Cir. 2012) (warning must make apparent harmful consequences and prompt reasonable precautions)
Felix v. Hoffman-LaRoche, Inc., 540 So. 2d 102 (Fla. 1989) (warnings judged by a reasonable-person standard)
Owens-Corning Fiberglas Corp. v. Ballard, 749 So. 2d 483 (Fla. 1999) (clear-and-convincing standard discussion in punitive-damages context)