Lawrence Ex Rel. B.J. v. Raymond Corp., 501 F. App'x 515

Lawrence injured her foot when a stand-up Raymond forklift backed away from a pallet and her foot was crushed against a column.
Forklift design includes a rear open entrance; a door for the rear entrance is sold separately and is supposed to keep objects out, not in.
Lawrence alleges defective design (no latching door) and failure to warn under Ohio law; Lowe’s pursued subrogation against Raymond and settled.
Expert Berry opined that a latching door on stand-up rear-entry forklifts is defectively designed and would have prevented Lawrence’s injury.
District court granted Raymond’s motions in limine and for summary judgment, excluding Berry’s testimony as unreliable, and Lawrence appealed.
Court affirms summary judgment for Raymond on both the design-defect and failure-to-warn claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Design defect—whether latching door was feasible and would prevent injury	Lawrence argues latching door would have prevented injury	Raymond contends Berry’s testimony unreliable and door impractical	Barry's testimony excluded; no triable issue on design defect
Admissibility and reliability of Berry’s expert testimony	Berry’s opinion not solely for litigation; compatible with design needs	Berry is a hired expert; not generally accepted; not tested for Raymond forklift	District court did not abuse discretion in excluding Berry; summary judgment upheld
Failure-to-warn duty—whether risk was open and obvious or not	Lawrence contends jarring risk required warning	Court found risk of crush injuries obvious; jarring risk not shown	Lawrence failed to raise genuine issue on duty to warn; claim fails

Newell Rubbermaid, Inc. v. Raymond Corp., 676 F.3d 521 (6th Cir. 2012) (expert admissibility under Rule 702 and Daubert factors; rigorous analysis allowed)
Kumho Tire Co. v. Carmichael, 526 U.S. 137 (U.S. 1999) (framework for evaluating expert reliability and methodology)
Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (U.S. 1993) (testing and acceptance of scientific theory; standard for reliability)
Johnson v. Manitowoc Boom Trucks, Inc., 484 F.3d 426 (6th Cir. 2007) (testing and methodology considerations for experts)
Francis v. Clark Equip. Co., 993 F.2d 545 (6th Cir. 1993) (product design defect standards; practical feasibility)
Dhillon v. Crown Controls Corp., 269 F.3d 865 (7th Cir. 2001) (factors for evaluating alternative designs)
Freas v. Prater Constr. Corp., 573 N.E.2d 27 (Ohio 1991) (duty to warn and open/obvious risks under Ohio law)