Appeals Court Upholds Summary Judgment Against Manufacturer in Evangeline Parish Products Liability Case

Companies manufacturing items that are inherently dangerous in the course of its normal use have certain legal obligations under products liability law. This case illustrates the necessary components of a successful products liability claim in Louisiana.

The plaintiff was working on a backhoe to clean out a drainage culvert when the clamps holding the vehicle’s hydraulic lines broke free and caused the lines to spew out hydraulic fluid. While attempting to reconnect the clamps, the plaintiff fell off the vehicle and was injured. He brought suit against the backhoe’s manufacturer and claimed that the company knew of the existence of an alternative design of the clamps that would better protect the hydraulic lines from leaking.

The trial court denied two separate motions for summary judgment by the defendant finding there were issues of material fact that precluded the granting of a motion for summary judgment. Subsequently, the plaintiff filed his own motion for summary judgment against the manufacturer under the Louisiana Products Liability Act (LPLA) which the court granted. The manufacturer appealed the trial court’s decision, and this appeal followed.

In Louisiana, the LPLA provides the only remedy against manufacturers for damage caused by their products. The appeals court points out that plaintiff must prove the following four things to establish a manufacturer’s liability under the LPLA:

(1) the defendant is the manufacturer of the product; (2) the claimant’s damage was proximately caused by a characteristic of the product; (3) this characteristic made the product unreasonably dangerous; and (4) the claimant’s damage arose from a reasonably anticipated use of the product by the claimant or someone else.

The manufacturer challenged the plaintiff’s assertions that it marketed an item that was inherently dangerous in the course of its normal use and that utilizing an alternative design would have prevented his injury. The appeals court disagreed with the defendants on all of their arguments.

The appeals court first found that the problem the plaintiff encountered with the clamps was the proximate cause of his injury. The court felt that the manufacturer failed to adequately rebut the plaintiff’s evidence that it was the clamps coming loose from the line that allowed the hydraulic fluid the plaintiff slipped in to leak from the lines.

The appeals court then found that the manufacturer failed to adequately rebut the plaintiff’s evidence that he was operating the backhoe in a reasonably foreseeable manner. The court points out that backhoes are marketed as heavy duty machines that are used in a variety of outdoor situations, so its use in this case was not unreasonable.

The appeals court also found that the manufacturer failed to adequately rebut the plaintiff’s evidence showing that hydraulic lines were themselves the defective. The manufacturer argued that the clamps alone were the problem, but the court was unconvinced and found that the manufacturer failed to rebut the plaintiff’s expert evidence that the entire hydraulic line was defective.

Finally, the appeals court addressed the issue of the existence of an alternative design. The issue of an alternative design only applies when the plaintiff was using the product in a reasonably foreseeable manner. The court had previously found that to be the case here, so the issue was applicable here. The plaintiff provided evidence that other products made by the manufacturer had an alternative hydraulic line design that decreases the possibility of leakage, and this meant the design that was at issue was unreasonably dangerous. The court once again finds that the defendant failed to rebut the plaintiff’s evidence on this matter.

In the end, the appeals court finds in favor of the plaintiff on every issue and affirms the trial court’s granting of a motion for summary judgment in favor of the plaintiff.

Products liability cases can be very complicated and require high quality legal representation. The Berniard Law Firm can provide just such representation in products liability cases.