DEJESUS v. KNIGHT INDUSTRIES & ASSOCIATES, INC.
2:10-cv-07434
E.D. Pa.Jul 26, 2013Background
- DeJesus and his wife sue Knight Industries for injuries from a Harley-Davidson factory accident involving a Knight lift table.
- DeJesus alleges defective design and negligence; Mrs. DeJesus asserts a loss of consortium claim.
- The accident occurred when a chain rack fell on DeJesus as a coworker raised the lift table; DeJesus sustained severe leg injuries and long-term recovery.
- Knight’s lift table allegedly lacked audible/visual warnings and warning stickers at the time of the incident.
- Knight moved to exclude plaintiffs’ expert Dr. Kevin Rider under Rule 702/Daubert and for summary judgment on all claims.
- The court granted both the motion to exclude Rider’s testimony and Knight’s summary-judgment motion on all principal claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether audio/visual warnings were a reasonable design defect | DeJesus argues warnings were required by a reasonable design alternative. | Knight contends warnings are feasible but not a reasonable design choice under Restatement Third. | Design defect claims fail; no reasonable alternative design shown. |
| Whether lack of warning stickers rendered the product defective | Rider’s view that missing stickers made table unsafe. | Evidence shows stickers were provided; no proof the specific table lacked them. | Failure-to-warn claim fails; no evidence table lacked warnings at injury time. |
| Whether Knight breached a duty of care via negligence | Defect in design/negligence caused injury. | No design defect; no breach given restraints of Restatement Third. | Summary judgment for Knight on negligence. |
| Whether loss of consortium claim survives | Derivative claim should stand if main claims proceed. | If principal claims fail, derivative should fail. | Loss of consortium dismissed with rest of claims. |
Key Cases Cited
- Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (U.S. 1993) (gives standard for admissibility of expert testimony)
- In re Paoli R.R. Yard PCB Litig., 35 F.3d 717 (3d Cir. 1994) (three-factor test for admissibility of expert testimony)
- Covell v. Bell Sports, Inc., 651 F.3d 357 (3d Cir. 2011) (Restatement Third guidance for design defect claims in PA)
- Morena v. S. Hills Health Sys., 501 Pa. 634 (Pa. 1983) (elements of common-law negligence in PA)