## Facts

- Arnaldo Medina bought a wooden pull-down attic ladder manufactured by Louisville Ladder, Inc. from Home Depot U.S.A., Inc.
- Medina installed the ladder himself in his residence.
- While descending the ladder, Medina fell and struck his elbow, allegedly suffering serious injury.
- Medina and his wife, Luz Lopez, alleged the ladder was defectively designed and/or manufactured and had inadequate warnings.
- The complaint asserted strict products liability and negligence claims against the manufacturer and retailer, plus a derivative loss-of-consortium claim by Lopez.

## Issues

1. Whether plaintiffs produced sufficient evidence that the attic ladder had a design defect, manufacturing defect, or warning defect to survive summary judgment under Florida law.
2. Whether plaintiffs produced sufficient evidence that an identified defect proximately caused Medina’s fall and injuries.
3. Whether, given the technical nature of the alleged ladder failure, plaintiffs could proceed without competent, admissible expert testimony on defect and causation.

## Decision

- The court granted summary judgment for Louisville Ladder, Inc. and Home Depot U.S.A., Inc. on all claims.
- The court held plaintiffs failed to present admissible evidence establishing a defect and failed to present admissible evidence establishing causation.
- The loss-of-consortium claim was dismissed as derivative of the failed underlying claims.

## Legal Principles

- On summary judgment, the nonmovant must present evidence creating a genuine dispute of material fact; speculation cannot defeat summary judgment.
- Under Florida products liability law, a plaintiff must prove (for strict liability) a product defect that rendered the product unreasonably dangerous and that the defect caused the injury; negligence similarly requires proof of breach and causation.
- In technically complex product cases, competent expert testimony is generally required to prove defect and causation; a jury may not infer defect and causation from the mere occurrence of an accident.
- Where multiple non-defect explanations (e.g., installation error, misuse) are plausible and the plaintiff cannot tie the incident to a specific defect with admissible evidence, causation fails as a matter of law.

## Conclusion

The court entered judgment for the manufacturer and retailer because the plaintiffs’ proof amounted to an accident plus lay assumptions, which could not establish defect or proximate causation for a technically complex ladder system under Florida law.


Medina v. Louisville Ladder, Inc., 496 F. Supp. 2d 1324 (M.D. Fla. 2007)