## Facts

- Lawnlite Co. manufactured aluminum outdoor furniture and sold it through retailers.
- Lawnlite sold and delivered a rocking lounge chair to a retail store in St. Petersburg, Florida.
- Gerald G. Matthews, a prospective purchaser, sat in the chair at the store to test it in an ordinary manner.
- While seated, Matthews placed his right hand on the chair’s right armrest; his third finger extended over and beneath the front end of the armrest.
- The chair’s concealed moving parts beneath the armrest severed Matthews’s finger.
- The moving mechanism was not visible to the user, and there was no warning or notice of the hazard.
- Matthews alleged negligent design and manufacture and failure to warn, asserting the chair was unreasonably dangerous in normal, foreseeable use.

## Issues

1. Whether a manufacturer may be liable in negligence to a foreseeable user or prospective purchaser injured by a concealed dangerous condition in the product, despite lack of contractual privity.
2. Whether allegations of concealed moving parts creating a foreseeable risk during ordinary use sufficiently state a cause of action to survive a motion to dismiss.

## Decision

- The Florida Supreme Court reversed the order dismissing Matthews’s second amended complaint.
- The court held the complaint stated a cause of action in negligence against the manufacturer.
- The case was remanded for further proceedings.

## Legal Principles

- A manufacturer owes a duty of reasonable care to persons who may reasonably be expected to use its product in a lawful and ordinary manner when negligent design or manufacture may foreseeably cause bodily harm.
- Lack of privity between the injured person and the manufacturer does not bar a negligence claim where the injury to a foreseeable user arises from a dangerous condition in the product.
- A concealed, non-obvious danger in a consumer product can support manufacturer liability; cases involving open and obvious hazards or user misuse are distinguishable.
- On a motion to dismiss, well-pleaded allegations are taken as true; a complaint alleging manufacture, distribution, concealed danger, foreseeable ordinary use, and resulting injury is sufficient to proceed.

## Conclusion

The court permitted the negligence action to go forward, reasoning that a manufacturer can be responsible to a foreseeable user injured during ordinary product testing when a chair’s concealed mechanism creates a hidden and foreseeable risk of serious injury, even without privity.


Matthews v. Lawnlite Co., 88 So. 2d 299 (Fla. 1956)