## Facts

- David Krajewski, a self-employed farmer, bought a set of three high-carbon steel rolling head pry bars from Northern Tool & Equipment Co., which sold the bars prepackaged from manufacturer Enderes Tool Co., Inc.
- While repairing a combine at dusk in poor light, Krajewski removed his tinted safety glasses to see better.
- He placed a pry bar against a shaft behind a sprocket and struck the pry bar with a metal hammer to dislodge the sprocket.
- On the first strike, a metal fragment chipped or splintered off and struck Krajewski’s right eye, causing serious injury.
- The packaging warned, “WARNING: Always Wear Safety Goggles”; the pry bar was stamped “wear safety goggles”; the hammer handle also warned to “wear safety goggles.”
- Krajewski testified he knew striking metal tools together can cause chipping and that this is why safety goggles should be worn.
- Krajewski sued Enderes and Northern Tool under Nebraska law for negligence, strict products liability, and breach of express warranty; only failure-to-warn theories (negligence and strict liability) were pursued on appeal after summary judgment for defendants.

## Issues

1. Whether the manufacturer’s and seller’s warnings to “Always Wear Safety Goggles” were adequate as a matter of law to satisfy any duty to warn of the risk of flying metal fragments when a pry bar is struck with a hammer.
2. Whether any alleged inadequacy in the warnings could be a proximate cause of the injury where the plaintiff read and understood the warnings, knew the specific risk, and nonetheless removed eye protection.

## Decision

- The Eighth Circuit affirmed summary judgment for Enderes and Northern Tool.
- The court held the warnings were clear and sufficient as a matter of law to alert a reasonable user to wear eye protection against the type of injury that occurred.
- The court concluded causation failed because Krajewski understood both the warnings and the underlying risk yet chose to proceed without eye protection; any additional warning would not have changed his conduct.
- The court agreed that Krajewski’s admitted knowledge of the hazard and voluntary exposure to it barred recovery on failure-to-warn theories under Nebraska law on these facts.

## Legal Principles

- Under Nebraska law, failure-to-warn claims (in negligence or strict liability) require proof that an inadequate warning proximately caused the injury.
- A warning may be adequate as a matter of law when it clearly instructs a precaution that would prevent the injury, even if it does not describe the precise mechanism of harm.
- When a plaintiff admits awareness of the specific hazard and disregards an explicit warning, the causal link between warning content and injury may be broken as a matter of law.
- A user’s subjective knowledge of the danger and voluntary decision to encounter it can defeat failure-to-warn liability where the warning communicates the relevant safety precaution.

## Conclusion

The court upheld summary judgment because the product materials plainly instructed the use of safety goggles and the plaintiff admitted he understood both the warning and the risk of chipping from striking metal tools together but removed his eye protection; therefore, any alleged warning defect could not be the legal cause of his injury.


Krajewski v. Enderes Tool Co., 469 F.3d 705 (8th Cir. 2006)