Sansom v. Crown Equipment Corp.
880 F. Supp. 2d 648
W.D. Pa.2012Background
- Sansoms sue Crown for design defect under Pennsylvania products liability with stockpicker model 30-SP-48TT-360.
- Sansom injured when stockpicker platform opened and allows fall; he failed to wear belt/lanyard at time of incident.
- Stockpicker lacks rear gate; European model has full perimeter guarding and rear gate.
- Crown produced 125 accident reports (1990–2007) showing serious injuries even with tethering; many fall without belt.
- Pennsylvania law governing products liability is unsettled; Third Circuit predicts Restatement Third governs design defect claims.
- Court denies Crown’s motion for summary judgment, applying Restatement Third (and also considering Restatement Second).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Governing law for design defect | Third Restatement applies per Covell guidance. | Second Restatement applies; design rule is different. | Genuine issues under Third; still analyzes Second for completeness. |
| Whether Stockpicker design is defectively designed under Restatement Third | Open load end creates foreseeable risk; rear gate exists elsewhere. | Current design reasonable; standards or alternative feasible design not required. | Genuine issues exist; could find defect with reasonable alternative design (rear gate). |
| Whether Stockpicker is unreasonably dangerous under Restatement Second | Open end and lack of gating render it unreasonably dangerous. | Device useful and adequately guarded; risk-benefit supports current design. | Notwithstanding, under Second, evidence supports unreasonableness as a matter of law. |
| Causation and assumption of risk | Causation from defect; assumption of risk issue for jury. | Assumption could bar claim when employee knowingly disregards precautions. | Causation genuine issue; avoidance of summary judgment on this point is appropriate. |
Key Cases Cited
- Covell v. Bell Sports, Inc., 651 F.3d 357 (3d Cir.2011) (apply Restatement Third Sections 1 and 2 for design defects)
- Berrier v. Simplicity Mfg., Inc., 563 F.3d 38 (3d Cir.2009) (predict Restatement Third governs bystander/defect analysis)
- Beard v. Johnson and Johnson, Inc., 41 A.3d 823 (Pa.2012) (Pennsylvania Supreme Court acknowledges disrepair; no contrary held)
- Schmidt v. Boardman Co., 11 A.3d 924 (Pa.2011) (discusses foundational concerns; continues Second Restatement framework)
- Azzarello v. Black Brothers Co., 391 A.2d 1020 (Pa.1978) (establishes risk-utility framework under Restatement Second)
- Surace v. Caterpillar, Inc., 111 F.3d 1039 (3d Cir.1997) (risk-utility factors (Wade) framework in Pennsylvania design defects)
- Phillips v. Cricket Lighters, 841 A.2d 1000 (Pa.2003) (discusses risk-utility and standards of caution)