## Facts

- Korey Stringer, a Minnesota Vikings offensive lineman, collapsed during July 2001 training camp in extreme heat and humidity and later died from multi-organ failure and complications of exertional heat stroke.
- On the first day, players practiced in “shells” (helmet, shoulder pads, shorts, jersey). Stringer completed morning practice but complained of an upset stomach and was observed vomiting during afternoon drills.
- Stringer experienced heat exhaustion, was removed from practice, and was taken to an air-conditioned trailer where he was given water but allegedly received no other first aid.
- On the next day, players practiced in similar conditions while wearing additional football pants with integrated pads; Stringer collapsed, was hospitalized, and died.
- Stringer used a helmet and shoulder pads manufactured by Riddell; the equipment used thick, dense padding intended to protect against impacts.
- The equipment included warnings, but did not warn of heat exhaustion or heat stroke risks associated with use in extreme heat.
- The estate alleged the equipment functioned like an insulating layer that impeded evaporation and heat dissipation, increasing Stringer’s body temperature.
- Plaintiff presented expert testimony that design and warning deficiencies increased heat-related risk and that adequate warnings could have changed team practice conditions and workload decisions.
- Riddell argued plaintiff lacked proof of a feasible safer alternative design and offered evidence that vented helmets were not cooler.

## Issues

1. Whether the helmet, shoulder pads, and related gear were defectively designed under Ohio products-liability law due to alleged heat trapping that contributed to fatal heat stroke.
2. Whether Riddell had a duty to warn about the specific risk of heat exhaustion and heat stroke when using the equipment in extreme heat, and whether lack of warning could be a proximate cause of death despite intervening decisions by coaches and trainers.
3. Whether the evidence supported express or implied warranty claims independent of the product-defect theories.

## Decision

- The court granted summary judgment for Riddell on the design-defect claims.
- The court granted summary judgment for Riddell on the breach of warranty claims.
- The court denied summary judgment on the failure-to-warn claim, allowing it to proceed.

## Legal Principles

- Under Ohio design-defect standards, a plaintiff generally must present evidence of a feasible alternative design and facts from which a jury could find the product unreasonably dangerous when balancing risk against utility.
- A failure-to-warn claim may proceed where the alleged hazard is a specific, serious risk that is not obvious to ordinary users, even if a more general risk (e.g., that protective gear makes a user hotter) is apparent.
- A manufacturer’s failure to warn is not categorically too remote to establish proximate cause merely because intermediaries (such as coaches and trainers) control use conditions; causation may be shown if it is reasonably foreseeable that adequate warnings would affect intermediary conduct in ways that reduce the risk.

## Conclusion

The court disposed of the products-liability case on summary judgment by dismissing design-defect and warranty theories for lack of sufficient supporting evidence, but it found a triable failure-to-warn claim because a jury could conclude the specific heat-stroke risk was non-obvious and that adequate warnings could foreseeably have changed team staff conduct and prevented the death.


Stringer v. Nat’l Football League, 749 F. Supp. 2d 680 (S.D. Ohio 2010)