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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.
2015
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Background

  • 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)
Read the full case

Case Details

Case Name: Genie Industries, Inc. v. Ricky Matak, Belinda Matak and Misty Sonnier, as Representative of the Estate of Walter Pete Logan Matak
Court Name: Texas Supreme Court
Date Published: May 8, 2015
Citation: 462 S.W.3d 1
Docket Number: 13-0042
Court Abbreviation: Tex.