Scott Weigle v. SPX Corporation
729 F.3d 724
7th Cir.2013Background
- Two mechanics (Weigle and Moore) were injured when an SPX OTC Tools 1779A support stand tipped and a trailer fell on them while they worked beneath it; neither mechanic used the removable support pin.
- The support stand design: conical base, extension tube with multiple pin holes, and a tethered support pin; when unpinned the extension tube can contact the ground and the stand becomes unstable.
- SPX supplied a printed "Parts List and Operating Instructions" and a warning decal on each stand stating in bold: always use the support pin (insert completely) and warning of personal injury if not followed, plus pictograms including a load falling on a person.
- Plaintiffs produced evidence that (1) many other jack-stand designs prevent the column from reaching the ground without a pin, (2) industry custom favors operating stands at the lowest possible height, and (3) an engineer opined that a simple, inexpensive design change (e.g., a permanent stop or pin) could have prevented the hazard.
- The district court granted SPX summary judgment, holding the warnings were adequate as a matter of law and, relying on Marshall v. Clark Equipment Co., that adequate warnings precluded a defective-design claim; plaintiffs appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of warnings | Warnings are inadequate because they do not explain the mechanics—i.e., that the stand becomes unstable if the extension column touches the ground without the pin | Warnings clearly and unambiguously require always using the support pin and warn of personal injury; plaintiffs’ requested extra "physics lesson" is unnecessary | Warnings were adequate as a matter of law; summary judgment on warning claims affirmed |
| Whether adequate warnings preclude defective-design claims | Even with adequate warnings, SPX should have designed a safer product (e.g., permanent stop); design defect remains triable | Adequate warnings absolve the manufacturer of liability for design defects (per district court reliance on Marshall) | Court vacated district court’s dismissal of design claims; adequate warnings are not a blanket defense to design defect under Indiana law; remanded for fact issues |
| Applicability of industry standards (ASME PALD) and engineer testimony | Noncompliance with ASME PALD and engineer opinion create genuine issues of material fact on defect and negligence | SPX disputes the engineer’s interpretation of ASME PALD and asserts compliance | Court held disputes over ASME PALD interpretation and other design evidence create triable issues; cannot resolve on summary judgment |
| Misuse defense / comparative fault | Plaintiffs: operating without pin was foreseeable; thus misuse is not a complete defense | SPX: plaintiffs misused product and are at fault, warranting summary judgment | Misuse is a fact question and an aspect of comparative fault; not appropriate for summary judgment here |
Key Cases Cited
- Cook v. Ford Motor Co., 913 N.E.2d 311 (Ind. Ct. App.) (warnings that are permissive or equivocal can create a factual issue on adequacy)
- TRW Vehicle Safety Sys., Inc. v. Moore, 936 N.E.2d 936 (Ind.) (discussing negligence/risk-utility principles and reasonable alternative design in defective-design claims)