When does a component-part manufacturer owe no duty, as a matter of law, to install safety features that an injured party alleges are necessary? Indiana Supreme Court justices answered that question Monday, reversing judgment previously entered for a national motor company on a defective design claim after a man was crushed by a semi that had no rearview safety features.
PACCAR, Inc. manufactures vehicles and parts that W&W Transport uses to conduct its trucking operations. One of its products includes a “glider kit,” which offers the body and frame of a semi truck. However, the glider kit has a 40-foot blind spot behind it, and PACCAR typically does not include safety measures to mitigate the danger.
In March 2016, a W&W semi-truck made from a gilder kit was backing up when it pinned and crushed Rickey Brewer, who had been standing directly behind the truck. His widow, Angela Brewer, filed a wrongful-death lawsuit against PACCAR, asserting a defective-design claim, alleging that PACCAR’s glider kit was unreasonably dangerous and defective because it lacked certain safety features and warnings relating to the blind spot.
The Morgan Circuit Court entered summary judgment for PACCAR, but the Indiana Court of Appeals reversed, finding the judgment improper. PACCAR asserted that summary judgment was appropriate because it had no duty, as a matter of law, to include the safety features that Brewer alleged were necessary. Brewer, on the other hand, countered that summary judgment in PACCAR’s favor was improper because the designated evidence showed the glider kit was defective when it left PACCAR’s control, given PACCAR’s failure to include certain safety features.
In response to oral arguments in the case, the Indiana Supreme Court held that under the Indiana Product Liability Act, a manufacturer who produces a component part with only one reasonably foreseeable use has no duty, as a matter of law, to install safety features if the final manufacturer was offered the safety features and declined them, or, if the component part, once integrated, could be used safely without those safety features.
But because PACCAR failed to establish the absence of a genuine issue of material fact for either condition, it was not entitled to summary judgment, the high court concluded.
PACCAR asserted that the duty to install certain safety features fell on the final manufacturer alone. But justices found that while a component-part manufacturer may have no duty to install such features if the component part is integrated into a final product that has multiple anticipated configurations, PACCAR’s glider kit had just one reasonably foreseeable use.
“The designated evidence indisputably shows that PACCAR’s sleeper-cab glider kit has one reasonably foreseeable use — to be combined with an engine, transmission, and exhaust system into an over-the-road semi,” Chief Justice Loretta Rush wrote for the unanimous panel. “And there is no reasonable dispute that an over-the-road semi with a sleeper cab is, at some point, going to be used in reverse, and that the glider kit — both as supplied and as integrated — has a forty-foot blind spot.
“… But this does not mean that a manufacturer of a component part with one reasonably foreseeable use will necessarily owe a duty, as a matter of law, to include allegedly necessary safety features.”
The Supreme Court noted that while there were two paths in which PACCAR could have found relief, it did not make a showing of either. It first found PACCAR did not provide anything to refute W&W’s response that it was not offered a list of options from which to identify or select the options that it desired, including safety features.
Likewise, the high court concluded PACCAR failed to show the absence of a genuine issue of material fact that the glider kit, once built out as an operable semi, could be used safely without the allegedly necessary safety features. Justices added that while certain safety features such as a back-up alarm may be ineffective, that doesn’t mean the component part manufacturer must have no duty to include other safety features, such as a back-up camera.
The Supreme Court concluded by noting that the sophisticated-user defense should be available to challenge design-defect claims. But such defenses are suited for the trier of fact, not for summary judgment, the justices noted.
The case was thus reversed and remanded for proceedings in Angela Brewer, Individually and as Personal Representative of the Estate of Rickey A. Brewer, Deceased v. PACCAR, Inc. d/b/a Peterbilt Motors Co., 18S-CT-451.