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
- Whether the sweeper’s sharp, unguarded edge created a foreseeable zone of risk giving rise to a duty to protect workers in the vicinity.
- Whether the edge could be found a legal (proximate) cause of the injury when the plaintiff contacted it only because of an intervening fall.
- 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.