Hatch v. Trail King Industries, Inc.
2011 U.S. App. LEXIS 18000
| 1st Cir. | 2011Background
- Trail King manufactured the N-12 trailer to ADS specifications; ADS used the trailers exclusively.
- Hatch was injured while unloading pipes from trailer No. 25019 after pins were removed and gates dropped.
- District court gave jury instructions treating a design-defect claim under Restatement § 404; the answer to a jury question further glossed the rule for fabricators following employer specs.
- Massachusetts law recognizes design-defect and negligence theories under implied warranty, with liability extending to third parties in certain circumstances.
- The district court instructed that a fabricator could be exempt from liability if the design was dictated by the buyer and the defect was not obviously dangerous; plaintiffs challenged this.
- The First Circuit affirmed, concluding the instructions aligned with Massachusetts law and did not abuse the motion in limine ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the instructions correctly apply Massachusetts law on design defect and implied warranty? | Hatch contends instructions misapplied law and harmed warranty claims. | Trail King argues instructions accurately reflected Restatement and Massachusetts law. | Yes; instructions were correct under Massachusetts law. |
| Does Massachusetts law treat a fabricator following buyer specifications as exempt from design-defect liability under implied warranty? | Implied warranty extends regardless of who designed the product; no carve-out for buyer-specified designs. | Restatement § 404 and Massachusetts precedent shield fabricators following buyer specs unless the specs are obviously dangerous. | Fabricator is not liable for design defect absent obvious danger when following buyer specs. |
| Was the motion in limine ruling properly affirmed given the evidence and theories? | Denial of the motion in limine admitted improper design-history evidence. | Massachusetts law support and the district court’s ruling were proper. | Affirmed; no abuse of discretion. |
| Should § 2-316A(4) exclusion of warranties apply to this case? | Ferragamo-type disclaimer principles bar implied-warranty exclusions for employees. | 2-316A(4) excludes disclaimers here; not applicable because there was no attempted exclusion by the seller. | Not applicable; disclaimer provision does not govern the case. |
| Did the sophisticated purchaser exception affect the implied warranty analysis? | ADS’s sophistication undermines warranty liability and supports exclusion. | Sophistication is not the controlling factor; liability turns on the 1994 product as marketed. | No, sophisticated-purchaser exception does not control; product was defective in its marketed form. |
Key Cases Cited
- Haglund v. Philip Morris Inc., 446 Mass. 741, 847 N.E.2d 315 (Mass. Supreme Judicial Court 2006) (implied warranty and design defect theory align with strict liability approach)
- Johnson Insulation, 682 N.E.2d 1323 (Mass. 1997) (implied warranty not limited by contract between buyer and seller in third-party contexts)
- Cumberland Farms, Inc. v. Drehmann Paving & Flooring Co., 520 N.E.2d 1321 (Mass. App. Ct. 1988) (expansion joints advisory—implied warranty context in contract settings)
- Moon v. Winger Boss Co., 287 N.W.2d 430 (Neb. 1980) (manufacturer not liable for design defect when following buyer's specifications unless obviously dangerous)