## Facts

- Clifton Garris bought a Ruger P89 semi-automatic pistol from a Maryland retailer in March 1999.
- At purchase, he received an instruction manual with multiple safe-storage warnings, a youth handgun safety notice, an offer of a free safety course (declined), and a lock box with a padlock.
- Garris stored the pistol under a mattress and kept a loaded magazine on a bookshelf, rather than using the provided lock box.
- In June 1999, three-year-old Jordan Garris found the pistol and magazine, inserted the magazine, and the pistol discharged, causing a fatal head wound.
- Melissa M. Halliday, Jordan’s mother and estate representative, sued the manufacturer in strict products liability for (a) design defect based on the absence of child-resistant features and (b) inadequate warnings.
- The trial court granted summary judgment for the manufacturer; the intermediate appellate court affirmed; the Maryland Court of Appeals granted review.

## Issues

1. Whether a manufacturer may be held strictly liable for design defect when a lawfully sold handgun functions as intended but allegedly lacks child-resistant safety features.
2. Whether public policy limits strict products-liability design-defect claims against handgun manufacturers to malfunction or to a narrow category of handguns viewed as unsanctioned for legitimate purposes.
3. Whether an adult owner’s unsafe storage contrary to warnings constitutes misuse that defeats foreseeability and proximate cause in a child-access shooting.
4. Whether the warnings and safety information provided were legally adequate to defeat a failure-to-warn claim.

## Decision

- The Maryland Court of Appeals affirmed summary judgment for Sturm, Ruger & Co.
- The court held the Ruger P89 was a lawful product that did not malfunction and was not defective merely because it lacked additional child-proofing features.
- The court declined to use tort law to impose a general design mandate for child-resistant handguns absent legislative action.
- The court treated the owner’s failure to secure the firearm, despite multiple warnings and provided safety devices, as misuse that broke the causal chain.
- The court concluded the warnings and safety materials were adequate as a matter of law.

## Legal Principles

- Strict products-liability design-defect doctrine generally targets product malfunction; a properly functioning handgun is not “defective” solely because it is capable of inflicting lethal harm.
- Public policy may constrain design-defect liability for ordinary, lawfully marketed handguns, while leaving open different treatment for a narrow class of low-quality, easily concealable handguns largely attractive for criminal use and lacking substantial legitimate utility.
- Where a purchaser disregards clear safe-storage warnings and available locking devices, the resulting child access may be treated as misuse that defeats foreseeability and proximate cause in strict liability.
- Adequate warnings and safety instructions can negate a failure-to-warn claim when the harm results from noncompliance with those warnings rather than informational deficiency.

## Conclusion

Maryland’s highest court held that a handgun manufacturer was not strictly liable for a child’s death where the firearm was lawfully sold, operated as designed, and the accident resulted from an adult’s failure to follow extensive warnings and use provided safety equipment, rather than from a product defect or inadequate warnings.


Halliday v. Sturm, Ruger & Co., 792 A.2d 1145 (Md. 2002)