Product Liability Watch: Linden, Jr. v. CNH America & Identifying Parties in a Liability Claim

Things just are not made how they used to be.

Because of the lower standards in production, there has been an increase in injuries suffered because of faulty products. Product liability actions may seem intimidating because they are usually a lawsuit against a manufacturer, but our product liability attorneys have the experience to take on big business when defective products result in serious injury or death.

Linden, Jr. v. CNH America is a case that shows the importance of properly identifying negligent parties.

Plaintiff in this case was operating a bulldozer that was manufactured by CNH. This bulldozer had a rollover protection system for safety purposes. The bulldozer began to roll causing the plaintiff to be thrown from it. Subsequently the bulldozer landed on the plaintiff’s legs causing him to suffer severe injuries.

Plaintiff alleged that the seatbelt inside the bulldozer was defective in the way it was manufactured, designed and the warnings associated with it. This seatbelt was made by one manufacturing company and then incorporated into the bulldozer. Plaintiff sued the manufacturer of the bulldozer, CNH America, LLC (“CNH”) and the manufacturer of the seatbelt Indiana Mills & Manufacturing, Inc. (“IMMI”).

As to IMMI, the manufacturers of the seatbelt, the court held that under Iowa law CNH can be held responsible for the defects to the seatbelt because “the seatbelt was a component part of the bulldozer.” Because of this rule, the case against IMMI was dismissed.

Thus, in the trial for this case the plaintiff argued that CNH was liable because there were inadequate warnings, there was a design defect, and a manufacturing defect. As part of the argument regarding the manufacturing defects, plaintiff argued that the buckle design was faulty.

The court here cites the difference between a manufacturing defect and a design defect. Where there is an unintended configuration it is classified as a manufacturing defect and where there is an intended configuration that generates accidental and unwanted results it is considered a design defect.

After the original trial, the court dismissed the manufacturing defect claim and the jury granted a directed verdict as to the other two claims. Plaintiff disagreed with this finding and appealed. He claimed that the jury instructions were inappropriate surrounding the sophisticated user doctrine, among other things.

The sophisticated user doctrine addresses the manufacturer’s duty to warn of potential dangers associated with the use of their products. This doctrine states that a manufacturer has no duty to warn users if the user knows or should know of the potential dangers associated with the use of the product. This is mostly applicable when the user is a professional who should be cognizant of the characteristics of the said product.

CNH argued that because the plaintiff’s occupation was a bulldozer operator, it could be assumed that he had particularized knowledge of the potential dangers associated with use of a bulldozer. Plaintiff argued that this instruction was incorrect because it did not address the seatbelt issue. However, this court affirmed the ruling of the lower court and found that there was no error in the jury instructions.

This court explained that the jury instructions are required to fairly and adequately represent the evidence and the law applicable to the case in the light of the issues presented. The only time that a court reverses a jury instruction is when, after they are reviewed in their entirety, an error is found that affected the substantial rights of the parties in the litigation.