Tiede v. Sunbeam Products, Inc, 5:23-cv-00907

Plaintiff Kristin Tiede sued Sunbeam Products, Inc. after sustaining third-degree burns allegedly caused by a Sunbeam heating pad she was using.
Tiede alleged the heating pad overheated unexpectedly, resulting in injuries requiring a skin graft.
Her complaint was limited to claims of design defect and negligence following her abandonment of other product liability theories.
Sunbeam moved for summary judgment, arguing that Tiede could not satisfy necessary elements for her remaining claims.
The key factual dispute was whether Tiede could prove the existence and feasibility of a safer alternative heating pad design.
The court addressed the motion for summary judgment and analyzed both the design defect and negligence claims under Texas law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Design defect—safer alternative	Safer designs (lower max temp, shorter shutoff, better insulation) are possible.	No evidence of a safer alternative design that meets legal standards.	For defendant; plaintiff did not meet burden re: safer design.
Economic/technological feasibility of alternative	Alternatives are feasible based on expert’s general statements.	No proof of economic or technological feasibility offered.	For defendant; no evidence provided by plaintiff on feasibility.
Negligence claim	Independent of design defect, based on Sunbeam’s risk assessment/conduct.	Duplicative of design defect claim; must also prove safer alternative.	For defendant; negligence claim fails with design claim.

Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard; burden-shifting framework)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (material fact standard for summary judgment)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (genuine dispute for summary judgment)
Uniroyal Goodrich Tire Co. v. Martinez, 977 S.W.2d 328 (Tex. 1998) (necessity of safer alternative design in products liability)
Am. Tobacco Co., Inc. v. Grinnell, 951 S.W.2d 420 (Tex. 1997) (negligence in product design requires showing safer alternative)