## Facts

- Joseph Stazenski was injured in a warehouse after falling from a forklift.
- During the fall, his wrist struck a sharp, exposed metal edge on an industrial floor sweeper manufactured by Tennant Company.
- The contact lacerated his wrist, injuring nerves and tendons and causing permanent impairment.
- Joseph and Virginia Stazenski sued Tennant alleging a design defect: the sweeper had a sharp, unguarded edge that created an unreasonable danger in an industrial workplace.
- To oppose summary judgment, plaintiffs submitted an affidavit from a mechanical-engineering professor opining that the sharp, unguarded edge was a dangerous design condition and that injuries like Stazenski’s were a reasonably foreseeable result.

## Issues

1. Whether the sweeper’s sharp, unguarded edge created a foreseeable zone of risk giving rise to a duty to protect workers in the vicinity.
2. Whether the edge could be found a legal (proximate) cause of the injury when the plaintiff contacted it only because of an intervening fall.
3. Whether competent expert evidence created a genuine issue of material fact on defect and causation sufficient to defeat summary judgment.

## Decision

- The appellate court reversed the trial court’s summary judgment for Tennant and remanded.
- The court held that a jury could find the injury within the foreseeable zone of risk created by an exposed sharp edge on equipment used around workers in a warehouse.
- The intervening fall did not, as a matter of law, sever causation; foreseeability of intervening events was generally for the trier of fact.
- The expert affidavit created triable issues regarding defective design and causation, making summary judgment inappropriate.

## Legal Principles

- Duty and legal causation may be established where conduct or product design creates a foreseeable zone of risk posing a general threat of harm to others; the exact manner of injury need not be foreseen in detail.
- An intervening event is not necessarily a superseding cause; whether it was foreseeable is typically a fact question.
- In design-defect litigation, competent expert testimony supporting unreasonable danger and foreseeable injury can create a genuine issue of material fact that precludes summary judgment on defect and proximate cause.
- On summary judgment, evidence must be viewed in the light most favorable to the nonmoving party; close questions of foreseeability and causation ordinarily go to the jury.

## Conclusion

The court held that a sharp, unguarded edge on industrial equipment could foreseeably injure nearby workers even if contact occurs after a workplace fall, and that plaintiffs’ expert evidence required a jury to decide duty, defect, and proximate cause rather than disposing of the case on summary judgment.


Stazenski v. Tennant Co., 617 So. 2d 344 (Fla. Dist. Ct. App. 2d Dist. 1993)