## Facts

- Mark Daniels, a high-school quarterback, suffered severe and permanent brain injuries during football practice after a head-to-head collision while wearing a Rawlings football helmet.
- The helmet caved in and showed an indentation after the collision; Daniels sustained a subdural hematoma and related brain damage.
- Daniels sued Rawlings under strict products liability for defective manufacture and under negligence/gross negligence for failing to warn that the helmet would not protect against subdural hematomas.
- Evidence indicated Rawlings knew helmets have serious limits in preventing certain brain injuries, knew consumers and parents commonly believed helmets protect against such injuries, and knew subdural hematomas were a recurring cause of football-related deaths.
- Daniels’s father testified he would not have allowed Daniels to play football had he known the helmet would not protect against the type of injury suffered.
- A jury found the helmet was defectively manufactured, the defect was a producing cause of injury, Rawlings’s failure to warn created an unreasonable risk of harm and was a producing/proximate cause, and the failure to warn constituted negligence and gross negligence.
- The trial court awarded $750,000 in actual damages and $750,000 in exemplary damages; Rawlings appealed.

## Issues

1. Whether legally and factually sufficient evidence supported the finding that the helmet was defectively manufactured and that the defect was a producing cause of Daniels’s injuries.
2. Whether Rawlings had a duty to warn of the helmet’s protective limitations against subdural hematomas, and whether the failure to warn was a producing/proximate cause of the injuries.
3. Whether the evidence supported a finding of gross negligence and an award of exemplary damages based on Rawlings’s failure to warn.

## Decision

- The appellate court affirmed the judgment for Daniels.
- The court held the evidence was sufficient to support the jury’s finding of a manufacturing defect and producing-cause causation.
- The court held the evidence supported a duty to warn of known protective limitations and supported the jury’s findings that failure to warn created an unreasonable risk and caused the injury.
- The court upheld the gross negligence finding and exemplary damages based on evidence that Rawlings knew of the serious risk and nonetheless chose not to warn.

## Legal Principles

- A manufacturer is strictly liable when a product contains a manufacturing defect and the defect is a producing cause of the plaintiff’s injury.
- A manufacturer may have a duty to warn when it knows (or should know) of serious dangers or limitations associated with foreseeable use, especially where ordinary users are unlikely to understand the risk.
- Failure to warn of known, serious risks may constitute negligence; when accompanied by conscious indifference to user safety, it can constitute gross negligence supporting exemplary damages.
- On appellate review of jury findings, evidence is evaluated under legal and factual sufficiency standards that defer to reasonable inferences supporting the verdict.

## Conclusion

The court affirmed a verdict imposing both compensatory and punitive damages where a football helmet’s manufacturing defect and the manufacturer’s failure to warn of known limitations against subdural hematomas were found to have caused catastrophic injury, and where the failure to warn supported gross negligence.


Rawlings Sporting Goods Co. v. Daniels, 619 S.W.2d 435 (Tex. Civ. App.—Waco 1981)