Syracuse Personal Injury Law Blog
People harmed by defective products have the right to seek compensation for their losses. Proving liability often requires expert testimony, but only certain parties are qualified to testify as experts, as explained in a recent ruling issued in a New York product liability case. If you or a loved one has been injured by a defective product, it is essential to consult a skilled Syracuse personal injury attorney to evaluate your potential claims.
Background of the Case
It is alleged that the plaintiff was injured while operating an ironworker machine (the “Ironworker”) at his place of employment. The Ironworker, a piece of industrial equipment used for metal cutting and fabrication, was manufactured by the defendant. The plaintiff claimed that a rear guard was missing from the machine, which caused a piece of stainless steel to strike him above the eye, resulting in severe and permanent injuries, including loss of vision.
Reportedly, the plaintiff filed suit in September 2020, asserting claims of design defect, manufacturing defect, failure to warn, and breach of warranty. Specifically, the plaintiff argued that the Ironworker was defectively designed because it did not include a rear guard, which would have prevented the incident. The plaintiff further alleged that the defendant failed to provide adequate warnings regarding the risks associated with operating the machine without a rear guard. Additionally, the plaintiff sought to exclude evidence related to prior workplace injuries and certain Occupational Safety and Health Administration records.
Allegedly, the defendant denied the allegations and moved for summary judgment, arguing that the Ironworker was not defective and that the plaintiff’s injuries resulted from improper use or modifications of the machine after its manufacture. The defendant also sought to preclude the plaintiff’s expert testimony and evidence of post-manufacture modifications.
Evidence in Product Liability Cases
The court first addressed the admissibility of the plaintiff’s expert testimony. Under Rule 702 of the Federal Rules of Evidence, expert testimony must be relevant and reliable. The defendant argued that the plaintiff’s expert failed to provide sufficient data to support his opinions about the Ironworker’s design and the need for a rear guard. However, the court rejected this argument, noting that challenges to an expert’s methodology or conclusions pertain to credibility and weight, not admissibility. The court held that the expert’s testimony met the threshold for reliability and could be presented to the jury.
The court also reviewed evidence of post-manufacture modifications. While Rule 407 generally excludes evidence of subsequent remedial measures, the court noted that this rule does not apply to modifications made before the plaintiff’s injury. The court allowed evidence of pre-accident modifications to support the plaintiff’s argument that the defendant failed to warn of known risks associated with the Ironworker. However, the court limited the admissibility of this evidence, requiring the plaintiff to first prove that the defendant had prior notice of the danger.
Additionally, the court ruled on the plaintiff’s motion to exclude OSHA records and workers’ compensation documents. The plaintiff argued that certain OSHA records contained hearsay statements and were irrelevant to the case. The court agreed, precluding specific OSHA forms and handwritten notes that lacked trustworthiness or pertained to unrelated safety issues, such as missing front guards. The court also excluded evidence of the plaintiff’s prior workplace injuries, finding it irrelevant to the incident at issue and potentially prejudicial.
Ultimately, the court granted the defendant’s motion for summary judgment in part, dismissing the plaintiff’s manufacturing defect claim for lack of evidence. The court found that the plaintiff failed to demonstrate that the Ironworker deviated from its intended design or specifications. However, the court allowed the plaintiff’s design defect and failure-to-warn claims to proceed to trial, noting that questions of fact remained regarding the absence of a rear guard and whether the defendant had a duty to warn users of associated risks.
Confer With an Experienced Syracuse Personal Injury Attorney
If you or a loved one suffered harm due to a defective or dangerous product, it is critical to have experienced legal representation on your side. The experienced Syracuse personal injury attorneys at DeFrancisco & Falgiatano Personal Injury Lawyers have the skills and resources to help victims of defective products pursue the compensation they deserve, and if you hire us, we will work tirelessly on your behalf. You can contact us today at 833-200-2000 or visit our website to schedule a consultation.