Summary Judgment Granted In Products Liability Case

Summary Judgment was granted to various Defendants in the strict liability case of Zielinski v. Mega Mfg., Inc.,  No. 2:18-CV- 05113-JDW (E.D. Pa. Oct. 9, 2020 Wolfson, J.). 

According to the Opinion, the Plaintiff’s decedent died in a workplace accident when a table on which he was loading metal sheets upended the sheets fell upon the Plaintiff and killed him. 

The Plaintiff was working at a manufacturing plant and was using a machine to stamp sheet metal. 

The record indicated that, when the manufacturing plant had purchased the machine, the Defendant machine manufacturer informed the facility that it had to supply tables and material handling devices to be used with the stamping machine. The manufacturer prepared specifications to guide the design of such a table. However, it was emphasized in the Opinion that that manufacturer did not build, certify, or otherwise take responsibility for the creation of the table. 

The manufacturing plant where the decedent worked bought a table from a Co-Defendant. It was indicated that the Co-Defendant’s specifications called for the table to be anchored to the floor. However, the manufacturing plant did not do so and instead installed casters. At the time of the incident, the decedent was transferring sheets to the table when the table tipped and the sheets of metal fell upon the decedent. 

The court noted that there was no evidence presented as to what caused the table to upend. 

The decedent’s wife had filed a wrongful death and survival action against, in part, both the manufacturer of the machine and the manufacturer of the table under claims for strict liability and negligence. 

In entering summary judgment, the court noted that the manufacturer’s product, which was the machine used to stamp sheet metal, did not injure the decedent. It was also noted that that Defendant did not manufacture, supply, sell, or even recommend the particular table that upended. 

The court found that Pennsylvania law did not hold that manufacturer of the stamp machine strictly liable for failing to warn under the circumstances presented. It was additionally noted that that manufacturer did not have the duty to warn just because it had recommended the size of the table needed to make its machine work. Furthermore, that manufacturer Defendant did not require its customers to use any type of material tables and it was noted that workers could also simply stack materials on the floor or onto a forklift. 

The court additionally noted that the Plaintiff did not offer any evidence that the alleged defeat with the stamp machine, or any lack of any warning, was the proximate cause of the decedent’s death. 

The court additionally ruled that the Plaintiff’s claims against the maker of the table failed because that Defendant did not manufacture the table with casters or approve the change to the use of the table by the manufacturing plant. 

The court noted that, even if the table caused the decedent’s death, it was not the same type of table that that Defendant had sold to the facility since it had been modified. The court additionally noted that the manufacturing plant’s modifications to the table fell under the warnings about the use of the table. 

As stated, summary judgment was granted in favor of both Defendants. 

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Source: “Digest of Recent Opinions.” Pennsylvania Law Weekly (Oct. 27, 2020).