Culley v. Edwards Manufacturing Company of Albert Lea

Background

Edward Culley sued Edwards Manufacturing Company of Albert Lea under several product-liability theories and for breach of express and implied warranties. Culley was injured on December 9, 2017, while using the company’s ironworker machine at work. A piece of metal was dislodged from the machine’s punch station, flew into his safety goggles, knocked them upward, and lodged in his left eye.

The machine originally had a front plexiglass shield, but that shield had been removed when Culley was injured and was reinstalled afterward. Later inspection showed that the punch had broken and that the die had been lifted from its seat and set at an angle. Evidence also indicated that the manufacturer had redesigned the machine in 2006 or 2007 to include a rear guard, although the machine involved in Culley’s injury did not have one.

Claims Deemed Abandoned

The company argued that Culley had abandoned his manufacturing-defect claim and his express- and implied-warranty claims because his opposition to summary judgment did not address the company’s arguments concerning those claims. The court agreed and deemed those claims abandoned.

The court therefore granted the company’s motion for summary judgment on the manufacturing-defect and express- and implied-warranty claims, with those claims dismissed.

Design-Defect Claims

Culley’s remaining design-defect claims proceeded under strict-liability and negligence theories. The court explained that a design-defect plaintiff must show that the product was not reasonably safe as designed, that a safer design was feasible, and that the defective design substantially contributed to the injury.

The company relied on testimony from Culley’s expert that a similar machine was safe and that the hazard was reduced when the machine was fitted with its original guard. Culley argued that the expert’s testimony had been taken out of context and that the expert’s report supported adding a rear guard.

The court found genuine disputes of material fact about whether the ironworker required a rear guard in addition to its original front guard and whether a rear guard would have prevented Culley’s injury. Because those disputes required evaluation of the evidence by a jury, the court denied summary judgment on Culley’s strict-liability design-defect claim. The conclusion also states that summary judgment was denied as to Culley’s design-defect claims generally.

Failure-to-Warn Claims

A failure-to-warn claim requires proof that the manufacturer had a duty to warn about a danger connected to a foreseeable use, knew or should have known about the danger, and failed to provide a warning that proximately caused the injury.

The company argued that Culley had identified no required warning and had produced no evidence that a warning could have prevented his injury. Culley argued that the owner’s manual and the machine lacked warnings about dangers caused by a misaligned die and punch. He also relied on evidence that the company had redesigned the machine years earlier to include a rear guard.

The court found a genuine dispute about whether the company knew of the danger associated with using the ironworker without a rear guard. Viewing the evidence in Culley’s favor, the court concluded that a reasonable jury could find that the company knew by 2006 or 2007 that the absence of a rear guard presented a hidden danger during foreseeable use. The court therefore denied summary judgment on the failure-to-warn claims.

Disposition

The court granted in part and denied in part the company’s motion for summary judgment. It granted the motion as to the manufacturing-defect and express- or implied-warranty claims and denied the motion as to the design-defect and failure-to-warn claims. The clerk was directed to terminate the motion, and the court scheduled a telephonic pretrial conference for May 31, 2024.