Estabrook v. Mazak Corporation, 1:16-cv-00087

Background

Plaintiff Bradley Estabrook, a maintenance engineer at General Products, was injured on November 11, 2014 when a robot from a Mazak Flexible Manufacturing System (FMS) sheared and crushed his right leg while he was repairing a Mazak FH6800 CNC machine that interfaced with the FMS.
The FH6800 machines and the FMS were manufactured, customized, installed, serviced, and repaired by defendant Mazak Corporation; the machines were installed before Estabrook began work in 2006.
Plaintiff alleges Mazak designed a gap/alteration in the FH6800 to interface with the FMS, creating a defective design and failing to warn about hazards when the two systems were interfaced.
Plaintiff followed lock-out/tag-out procedures on the FH6800, but the connected FMS remained operational; plaintiff claims the interface and lack of warnings caused the injury.
Claims: Counts for defective design and failure to warn under the Indiana Products Liability Act (IPLA), and a negligence/post-sale-repair theory; Mazak moved to dismiss under Fed. R. Civ. P. 12(b)(6).
Court denied Mazak’s motion to dismiss, finding the Second Amended Complaint plausibly alleged IPLA defects and provided sufficient notice to survive pleading-stage dismissal.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether IPLA claims for design defect and failure to warn are plausibly pleaded	Estabrook alleges Mazak altered/designed FH6800-FMS interface (gap/removed guard) and failed to provide equipment-specific warnings, causing injury	Mazak contends allegations are insufficient and fault lies with employer safety (lock-out/tag-out) not manufacturer	Court: Claims plausibly pleaded under IPLA; factual causation and employer duties are not resolved at motion to dismiss
Whether Mazak had a duty to implement lock-out/tag-out procedures	Estabrook does not base liability on failing to implement employer OSH procedures; he alleges dangerous design/warning defects in the interfaced product	Mazak argues it had no duty to implement IOSHA procedures and that employer’s failure precludes liability	Court: Whether employer compliance/supervision was proximate cause is a factual question; not grounds for dismissal now
Whether negligence/post-sale repair theory is barred or subsumed by IPLA	Estabrook alleges Mazak’s post-sale repairs/rebuilds caused or introduced defects extending useful life	Mazak argues IPLA subsumes negligence/post-sale theories and seeks dismissal of separate negligence claim	Court: Claims merge under IPLA; but plaintiff may proceed—dismissal of the pleading is improper at this stage
Sufficiency of pleading under Twombly/Iqbal (Rule 12(b)(6))	Estabrook contends complaint gives factual content to infer Mazak’s liability	Mazak contends allegations are conclusory and lack factual specificity to be plausible	Court: Complaint meets Twombly/Iqbal plausibility standard; accepts well-pleaded facts and draws reasonable inferences for plaintiff

Key Cases Cited

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (grounds for pleading; plausibility standard)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading must plead factual content making claim plausible)
Gibson v. City of Chicago, 910 F.2d 1510 (Rule 12(b)(6) tests sufficiency, not merits)
Whirlpool Financial Corp. v. GN Holdings, Inc., 67 F.3d 605 (accept well-pleaded allegations and reasonable inferences)
Land v. Yamaha Motor Corp., 272 F.3d 514 (diversity jurisprudence; apply state substantive law)
Nat. Gas Odorizing, Inc. v. Downs, 685 N.E.2d 155 (elements to establish IPLA claim)
Cook v. Ford Motor Co., 913 N.E.2d 311 (design defect and failure to warn governed by manufacturer’s duty of reasonable care under IPLA)