Genie Industries, Inc. v. Ricky Matak, Belinda Matak and Misty Sonnier, as Representative of the Estate of Walter Pete Logan Matak
462 S.W.3d 1
Tex.2015Background
- Genie’s AWP-40S aerial lift was designed to be small, light, portable, and wielded by a single person.
- The base is narrow; outriggers with leveling jacks stabilize the lift; an interlock prevents operation unless outriggers are set.
- A worker on the platform was killed when the lift tipped after attempting to move with outriggers released while elevated.
- The plaintiffs alleged a design defect and a safer alternative design; the jury found liability against Genie and apportioned fault among Genie, the Church, Gulf Coast, and Matak.
- The trial court entered judgment for Genie; the court of appeals affirmed the design-defect finding and Genie appealed to the Supreme Court.
- The Court reversed, holding the lift was not unreasonably dangerous as designed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the AWP-40S was unreasonably dangerous as designed | Mataks contend risks outweigh utility, due to misuse despite warnings | Genie argues risks do not outweigh utility; design is not unreasonably dangerous | Not unreasonably dangerous as designed |
| Whether a safer alternative design existed and could be deemed feasible | Evidence supports several safer designs (automatic drop-down, pothole protection, block design) | Evidence of alternatives is weak and impractical; would impair utility | Some evidence of safer alternative designs; not conclusive but sufficient for jury consideration |
| Whether the risk-utility balance is a legal question or a jury factual question | Disagreement on risk-utility should go to the jury | Some aspects may be decided as a matter of law when only one reasonable conclusion exists | Risk-utility balancing generally factual for the jury; appellate review preserved the jury's verdict |
| Whether warnings and obvious dangers absolve liability for defective design | Despite warnings, misuse can render product unreasonably dangerous | Warnings and obvious risks negate liability under risk-utility framework | Warnings and obvious risks are factors; liability can still attach if risk-utility favors danger |
Key Cases Cited
- Caterpillar, Inc. v. Shears, 911 S.W.2d 379 (Tex.1995) (risk-utility balancing; not unreasonably dangerous as a matter of law when design changes affect utility)
- Timpte Indus., Inc. v. Gish, 286 S.W.3d 306 (Tex.2009) (rentention of risk-utility framework; misuse considerations remain relevant)
- Hernandez v. Tokai Corp., 2 S.W.3d 251 (Tex.1999) (misuse as a factor in risk-utility balancing; warnings and obvious risks are not absolutes)
- Uniroyal Goodrich Tire Co. v. Martinez, 977 S.W.2d 328 (Tex.1998) (warnings may be imperfect; jury may decide risk-utility with evidence of safer design)
- City of Keller v. Wilson, 168 S.W.3d 802 (Tex.2005) (zone of reasonable disagreement standard for reviewing jury verdicts)
