Steven Iliades v. Dieffenbacher North America Inc, 501 Mich. 326

Background

Plaintiff Steven Iliades, a trained press operator, was injured when he reached into a 500-ton Dieffenbacher rubber-molding press to retrieve fallen parts; he entered past the press’s light curtain while the press was in automatic mode and the cycle resumed, trapping him between platens.
The press had a presence-sensing light curtain that stops the press when beams are interrupted; Press No. 25 would automatically resume its cycle once the curtain was no longer interrupted.
Operators were instructed to switch the press to manual mode and use a parts grabber before reaching into the press; Iliades did not place the press into manual mode before reaching inside.
Iliades sued Dieffenbacher for negligence, gross negligence, and breach of warranty; Dieffenbacher moved for summary disposition arguing Iliades misused the press and that such misuse was not reasonably foreseeable under MCL 600.2947(2).
The trial court granted summary disposition for Dieffenbacher, finding misuse and unforeseeability; the Court of Appeals reversed (majority) using a criminal gross‑negligence foreseeability standard and deeming reliance on light curtains foreseeable; this Court granted review.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper legal test under MCL 600.2947(2): what steps must a court undertake when misuse is alleged?	Iliades argued misuse was a factual question for the jury; foreseeability should be judged broadly.	Dieffenbacher argued statute creates a two‑part judicial inquiry: (1) was there misuse under MCL 600.2945(e), and (2) if so, was that misuse reasonably foreseeable to the manufacturer.	The statute establishes a two‑part legal test: the court must first decide misuse, then decide whether that specific misuse was reasonably foreseeable.
Meaning of “misuse” under MCL 600.2945(e)	Iliades contended his conduct did not amount to unforeseeable misuse given workplace practices.	Dieffenbacher maintained Iliades’ act of entering past the light curtain while in automatic mode was misuse (use contrary to employer instruction and material deviation).	Misuse is defined by statute to include uses contrary to instructions, inconsistent with specs, or unsuitable uses; the court must determine whether Iliades’ conduct met that statutory definition.
Meaning of “reasonably foreseeable” in MCL 600.2947(2) — statutory or criminal standard?	Iliades (and Court of Appeals majority) favored a standard focused on common workplace practices; some argued for a stricter gross‑negligence benchmark.	Dieffenbacher urged application of common‑law foreseeability, measured at the time of manufacture, not a criminal gross‑negligence test.	The Court applied the common‑law meaning of reasonably foreseeable (what manufacturer knew or should have known at manufacture), and rejected importing a criminal gross‑negligence standard.
Application to summary disposition here: was reversal required?	Iliades argued factual disputes made summary disposition inappropriate.	Dieffenbacher argued undisputed evidence showed misuse and no reasonable foreseeability as a matter of law.	The Supreme Court reversed the Court of Appeals and remanded: because the Court of Appeals failed to decide whether Iliades’ conduct was misuse and used the wrong foreseeability standard, the appellate court must reconsider summary disposition under the two‑part statutory/common‑law framework.

Key Cases Cited

Samson v. Saginaw Professional Bldg., 393 Mich. 393 (1975) (defines foreseeability under Michigan common law)
Covenant Medical Center, Inc. v. State Farm Mutual Automobile Insurance Co., 500 Mich. 191 (2017) (principles of statutory interpretation)
Greene v. A P Products, Ltd., 475 Mich. 502 (2006) (discussed product misuse in duty‑to‑warn context)
Mach v. General Motors Corp., 112 Mich. App. 158 (1982) (foreseeability inquiry examines whether a use was common and whether manufacturer knew or should have known)