Pantazis v. Mack Trucks, Inc.
AC 16-P-1497
| Mass. App. Ct. | Nov 27, 2017Background
- Incomplete Mack truck (chassis, cab, engine) was sold in 1986 and later completed as a dump truck; decades later owner Mark Fidrych was found dead under the truck, clothing entangled in a spinning universal joint (U-joint) driven by a power take-off (PTO).
- Dana (now Parker-Hannifin by asset acquisition) manufactured the PTO; the installed auxiliary power system included an exposed auxiliary drive shaft and U-joint connecting the PTO to a hydraulic pump.
- Neither Mack nor Dana manufactured the auxiliary drive shaft or U-joint, and neither product was alleged to be defectively designed as sold.
- Both Mack and Dana provided warnings: Mack’s owner’s manual contained a PTO warning; Dana provided manuals and warning stickers advising not to go under the vehicle with the engine running and to avoid rotating drive shafts; Dana’s instructions left guard decisions to installers.
- Plaintiff (executrix of Fidrych’s estate) sued for wrongful death, alleging defendants had a duty to warn about risks from exposed auxiliary drive shafts/U-joints or voluntarily assumed such a duty; both defendants moved for summary judgment and prevailed in separate rulings, which were appealed and consolidated for review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether component manufacturers (Mack/Dana) owed a legal duty to warn about dangers created by downstream assembly (exposed auxiliary shaft/U-joint). | Mack/Dana should have warned because the transmission was designed to accept a PTO and PTO-driven auxiliary shafts were foreseeable; existing warnings show foreseeability. | Component parts doctrine: a manufacturer of a nondefective component has no duty to warn of dangers created solely by others’ assembly/installation decisions. | No duty as a matter of law; Mitchell controls—component manufacturers without defects are not liable for risks arising from subsequent assembly. |
| Whether defendants voluntarily assumed a duty to warn by supplying manuals/warnings. | Warnings provided show assumption of responsibility; at least factual dispute precluding summary judgment. | Any voluntary warnings were not a basis to assume broader duty to warn of downstream assembly risks; no negligent misrepresentation in warnings here. | No voluntary-assumption exception; defendants did not assume a legal duty by distributing manuals/stickers. |
| Whether foreseeability of downstream harms created a factual question for duty. | Foreseeability of using PTO with auxiliary shaft was factual and contested, so duty issue should go to jury. | Foreseeability does not convert the rule from Mitchell; policy forbids imposing duty on component sellers for special adaptations. | Court treated foreseeability here as a legal-policy determination; Mitchell’s rule applies and foreseeability does not create duty. |
| Whether an exception to the component-parts doctrine is warranted (e.g., based on special circumstances). | Plaintiff urged creating an exception to prevent release of dangerous machinery without warnings. | Defendants argued no good cause to create an exception; installers/assemblers or others could bear duty. | No exception recognized on this record; plaintiff failed to show good cause to carve one out. |
Key Cases Cited
- Mitchell v. Sky Climber, 396 Mass. 629 (Mass. 1986) (holds component-parts doctrine: manufacturer of nondefective component has no duty to warn of dangers created by subsequent assembly)
- Morin v. AutoZone Northeast, Inc., 79 Mass. App. Ct. 39 (Mass. App. Ct. 2011) (discusses possible exceptions to component-parts doctrine in different factual contexts)
- Bulwer v. Mount Auburn Hosp., 473 Mass. 672 (Mass. 2016) (standard for reviewing summary judgment; view evidence in light most favorable to nonmoving party)
- Afarian v. Massachusetts Elec. Co., 449 Mass. 257 (Mass. 2007) (duty is a question of law appropriate for summary judgment)
- Jupin v. Kask, 447 Mass. 141 (Mass. 2006) (duty analysis governed by social policy considerations)
- O'Sullivan v. Shaw, 431 Mass. 201 (Mass. 2000) (recognizes open-and-obvious doctrine in duty-to-warn cases)
- Jones v. Boykan, 74 Mass. App. Ct. 213 (Mass. App. Ct. 2009) (procedural rule on final judgments and Rule 54(b) implications)