## Facts

- Vincent E. Hughes was severely burned when a gas stove in his mobile home exploded.
- The stove was manufactured by Magic Chef, Inc. and connected to a propane supply.
- After the propane tank ran empty and was refilled, two stove pilot lights were relit, but a third pilot light in the oven broiler cavity was not reignited.
- Plaintiffs’ evidence attributed the explosion to propane accumulation in the stove that ignited when Hughes later attempted to use it.
- Hughes and his wife sued under strict products liability, alleging the stove was defective and unreasonably dangerous.
- Magic Chef asserted product misuse and assumption of risk based on the manner of use and plaintiff’s knowledge.

## Issues

1. Whether the strict-liability instruction erroneously required the plaintiff to prove the defect was not discoverable by ordinary inspection.
2. Whether product misuse is an affirmative defense or instead part of the plaintiff’s burden to show reasonably foreseeable use.
3. Whether the assumption-of-risk instruction was erroneous for failing to require actual knowledge of the specific danger and voluntary exposure to it.

## Decision

- The Supreme Court of Iowa reversed the defense verdict and remanded for a new trial.
- The court held it was error to instruct that the plaintiff must prove the defect was not discoverable by ordinary inspection.
- The court held misuse is not an affirmative defense in Iowa strict-liability actions; it relates to whether the product was used in a manner reasonably foreseeable to the manufacturer.
- The court held the assumption-of-risk instruction was erroneous because it did not adequately require proof that Hughes knew of the specific danger and voluntarily encountered it.
- The instructional errors were prejudicial and required a new trial.

## Legal Principles

- In strict products liability under Restatement (Second) of Torts § 402A, contributory negligence consisting of failure to discover a defect or guard against its existence is not a defense and should not be imported through jury instructions.
- “Misuse” is addressed through the plaintiff’s prima facie burden to show the product was used in a reasonably foreseeable manner; the relevant foreseeability is what the manufacturer should anticipate.
- Assumption of risk remains available in strict liability only when the plaintiff actually knows of the specific danger and voluntarily and unreasonably proceeds to encounter it; constructive knowledge or generalized carelessness is insufficient.
- Jury instructions that blur the boundary between non-bar defenses (contributory negligence) and bar defenses (assumption of risk) in strict liability can constitute reversible error.

## Conclusion

The court ordered a new trial because the jury instructions improperly required proof that the defect was undiscoverable by ordinary inspection, mischaracterized misuse as an affirmative defense rather than a foreseeability element, and failed to limit assumption of risk to a voluntary encounter with a known, specific danger.


Hughes v. Magic Chef, Inc., 288 N.W.2d 542 (Iowa 1980)