## Facts

- Virginia Mae Knitz worked for Toledo Die and Manufacturing Company operating punch presses.
- She was assigned to a 60-ton open-back inclinable punch press manufactured by Minster Machine Company.
- The press was originally shipped with a two-hand button-tripping device intended to keep the operator’s hands away from the point of operation during activation.
- At the time of the injury, the employer had disconnected the two-hand control and the press was operated by a floor foot pedal; a pull-back wrist guard was available but was not being used by Knitz.
- During a production run requiring hand placement of metal blanks between die halves, Knitz returned from getting a stool and found the scrap bin emptied and the foot switch moved.
- While leaning on the bolster plate with her right hand, Knitz attempted to reposition the foot pedal with her foot and inadvertently activated it, causing the ram to descend and amputate two fingers.
- Knitz sued Minster in strict products liability, alleging defective design due to (1) susceptibility of the foot pedal to accidental tripping and (2) lack of a point-of-operation guard when operated by foot control.

## Issues

1. What standard governs whether a product is defectively designed for purposes of strict products liability in Ohio.
2. Whether, under that standard, the manufacturer was entitled to summary judgment or whether genuine issues of material fact existed as to defective design based on accidental foot-pedal activation and lack of point-of-operation guarding in foot-pedal operation.

## Decision

- The Supreme Court of Ohio reaffirmed a dual standard for design defect: consumer-expectation and risk–benefit.
- The court held that the record, including expert evidence, created genuine issues of material fact on whether the press’s design was defective by permitting accidental foot-pedal tripping and by lacking point-of-operation guarding when the foot pedal was used.
- The court reversed summary judgment for Minster and remanded for further proceedings.

## Legal Principles

- A product design is defective if it is more dangerous than an ordinary consumer would expect when used in an intended or reasonably foreseeable manner, or if the benefits of the challenged design do not outweigh the risks inherent in the design.
- A product may be found defective in design under a risk–benefit inquiry even if it satisfies ordinary consumer expectations.
- In design-defect cases, summary judgment is improper where competent evidence permits reasonable minds to differ on whether the design created an unreasonable risk in reasonably foreseeable use.
- Employer modifications or nonuse of available safety devices may bear on causation and fault allocation, but do not necessarily eliminate design-defect questions as a matter of law when the challenged mode of operation is reasonably foreseeable.

## Conclusion

The court clarified Ohio’s strict-liability design-defect test as a disjunctive consumer-expectation or risk–benefit standard and held that disputed facts concerning foreseeable accidental foot-pedal activation and the absence of point-of-operation guarding required jury resolution rather than summary judgment.


Knitz v. Minster Mach. Co., 69 Ohio St. 2d 460, 432 N.E.2d 814 (Ohio 1982)