Minnesota Supreme Court Issues Anti-Manufacturer Decision in Products-Liability Case and Grants Review in Another Significant Case for Product Manufacturers
The Minnesota Supreme Court recently took action in two products-liability cases we have been monitoring.
First, the court issued its decision in Montemayor v. Sebright Products, Inc., A15-1188 (July 12, 2017), a case stemming from an incident in which a worker's legs were crushed while attempting to manually unjam a high-density food extruder used to make hog feed when a coworker turned on the machine. It was undisputed that the worker and his coworker both ignored safety warnings on the machine and that a safety device on the machine had been disabled. In a 4-3 decision, Supreme Court held that there was a genuine issue of material fact as to whether the risk of injury was reasonably foreseeable to the manufacturer, making the issue of foreseeability “close” and thus an issue for the jury. The majority reasoned based in part on conflicting expert reports that reasonable persons might differ as to the foreseeability of the worker's injury under the circumstances.
Shortly before issuing its decision in Montemayor, the supreme court granted further review in Great Northern Insurance Company v. Honeywell International, Inc., 895 N.W.2d 255 (Minn. App. 2017), a another significant products-liability case for product manufacturers.
Following a house fire, the homeowners' insurer commenced a products-liability action against the seller and the manufacturer of a heat-recovery ventilator (HRV), as well as the manufacturer of the HRV's motor. The district court granted summary judgment in favor of the motor manufacturer, holding that the insurer's product-liability and breach-of-warranty claims were barred under the ten-year statute of repose for improvement to real property—Minn. Stat. § 541.051, subd. 1—and that the motor manufacturer did not have a post-sale duty to warn. The court of appeals reversed. The motor manufacturer successfully petitioned the supreme court for further review. While it may be that the supreme court is most interested in addressing the statute of repose issue, it will more than likely address the post-sale duty to warn issue as well.
Read our full analysis of the opinions here.