Alabama Product Liability: Linden, Jr. v. CNH America Explains The Sophisticated User Doctrine

Manufacturers are just not making products like they used to. This is seen with the rising number of product liability cases in the courts. Our experienced Montgomery product liability attorneys understand the intricacies involved in these cases, and we can help you get the results you deserve.Negligent manufacturers should not be able to get away with lower safety standards in the design and manufacturing of their products because by allowing this we are feeding into this negative cycle of faulty production. Do not be intimidated to file your Montgomery product liability case.

Linden, Jr. v. CNH America is an appeal that arose because a man was injured when he was thrown off of a bulldozer. Upon falling off, the bulldozer fell on his legs causing serious injuries. Plaintiff sued the manufacturer of the seatbelt in the bulldozer, Indiana Mills & Manufacturing, Inc. (“IMMI”) and the manufacturer of the bulldozer, CNH America, LLC (“CNH”). He claimed that the seatbelt had a defective design, manufacturing defect and insufficient warnings.

The initial court cited Iowa statute that held that where there is a faulty component part manufactured by one manufacturer but incorporated into another product, the manufacturer that used the faulty product as a component part can be held liable.

IMMI manufactured the seatbelt that was used as a component part in the manufacturing of the bulldozer by CNH. Because of the Iowa statute discussed above, CNH was held liable for any injuries that resulted because of a faulty product manufactured by IMMI.

Thus in plaintiff’s case against CNH, the court discussed the intricacies of manufacturing and design defects. The court then dismissed the plaintiff’s manufacturing defect claim and the jury in the case granted a directed verdict for the defendant on the claims of insufficient warnings and design defect. Plaintiff appealed this decision and arguing that the court erred in their jury instructions as well as in their finding.

The higher court in Linden discusses the appropriateness of the jury instructions in the original trial. The court had instructed the jury regarding the sophisticated user doctrine and the plaintiff argued, that the court failed to give a specific standard regarding negligence for the faulty seatbelt.

The sophisticated user doctrine is used to establish a manufacturer’s duty to warn product users of potential dangers associated with the use of their products. Under this theory, a manufacture does not have a duty to warn users of their product if the user knows or should know of the potential dangers involved in using the product. This is most commonly seen where the product user is a professional and would be assumed to know the characteristics of the product.

Because in this case the plaintiff was a professional bulldozer driver, the court found that they jury instruction which led to the discussion of this standard was adequate. The seatbelt is considered part of the bulldozer. Therefore, it could be assumed that a professional bulldozer driver would understand the faulty nature of the bulldozer seatbelt.

This court found that the logic was reasonable in the jury instructions and the plaintiff failed to provide the appropriate evidence to support his contention of manufacturer’s duty.

Product liability can seem complex but with the right attorney, you can present the right evidence and prove your case.
