Facts
- A father purchased an electric steam vaporizer manufactured by Hankscraft Company for use in his young child’s bedroom to humidify the room on a doctor’s advice.
- The parents read and followed the manufacturer’s written instructions in operating the device.
- The vaporizer heated water to near boiling and emitted steam; evidence indicated the unit could tip or the plastic top could be displaced, causing a sudden discharge of near-boiling water.
- The written instructions and warnings did not adequately alert users to the risk of scalding or specify precautions appropriate to foreseeable use around small children.
- The child suffered severe burns when hot water escaped from the vaporizer.
- A jury found for the plaintiff on negligence and breach of express warranty and awarded $150,000.
- The trial court granted judgment notwithstanding the verdict (JNOV) and conditionally granted a new trial in a general order that did not specify grounds.
Issues
- Whether the evidence, viewed most favorably to the verdict, was sufficient to support liability for negligent design and failure to warn.
- Whether the evidence was sufficient to support liability for breach of express warranty based on the manufacturer’s written representations.
- Whether the trial court properly granted JNOV under the governing standard.
- Whether a conditional new-trial order could stand when it stated no specific grounds, including on the claim that damages were excessive.
Decision
- The Minnesota Supreme Court reversed the JNOV, holding the evidence permitted a reasonable jury to find for the plaintiff on negligence and express warranty.
- The court reversed the conditional new-trial order because it lacked articulated grounds and the record supported the verdict.
- The court reinstated the $150,000 jury verdict, finding no showing that the award resulted from passion or prejudice.
Legal Principles
- JNOV is proper only when the evidence is practically conclusive against the verdict; courts must view the evidence and reasonable inferences in the light most favorable to sustaining the verdict.
- A manufacturer must exercise reasonable care in product design and warnings where foreseeable use presents serious risks, including use in the presence of small children.
- Failure-to-warn liability may rest on inadequate warning of non-obvious dangers associated with foreseeable use.
- Express warranty may arise from a manufacturer’s written affirmations or representations about safe or suitable use; liability may follow if the product fails to conform and the breach causes injury.
- An order granting a new trial should rest on specific stated grounds; a general, unexplained order may be reversed where the record supports the verdict.
- A damages award is not set aside as excessive solely due to its size absent indications of passion, prejudice, or lack of evidentiary support.
Conclusion
The court reinstated a jury verdict for a child injured by a steam vaporizer, holding that the evidence supported findings of negligent design, failure to warn, and breach of express warranty, and that neither JNOV nor a general conditional new-trial order was justified on this record.