Monday, November 11, 2013

Hood v. Ryobi America Corp. case brief

Hood v. Ryobi America Corp. case brief summary
181 F.3d 608 (4th. 1999)

Plaintiff consumer appealed an order from the United States District Court for the District of Maryland, at Baltimore, which granted defendant manufacturer's motion for summary judgment, in plaintiff's action against defendant for strict product liability and failure to warn.


Plaintiff consumer purchased defendant manufacturer's miter saw, removed the blade guards, and soon after while using the saw accidentally cut off part of his thumb.


  • Holding that defendant provided adequate warnings against using the saw without the guards, and did not manufacture a defective product, the court affirmed the judgment. 
  • The court cited seven warnings on the tool or in the operator's manual against using the saw without the guards. 
  • The court stated that under Maryland law, the warning need not contain a specific description of what harm might occur if a product was misused, and held that warnings describing serious injury were sufficient. The court also held that the fact that the saw blade came off its spindle after plaintiff removed the guards did not make it a defective product. 
  • The court held that plaintiff's injuries were the direct result of his alteration of the tool. 
  • The court stated that strict liability was conditioned upon the product reaching the user without substantial change in the condition in which it was sold, and that a manufacturer was not liable in negligence if an intervening alteration of the product was the superseding cause of injury.


The court affirmed the judgment for defendant manufacturer, because defendant met its duty to warn by placing on the saw and in the manual numerous warnings of possible serious injury resulting from removal of the blade guards, and because defendant was not strictly liable or negligent where plaintiff consumer's intervening alteration of the product was the superceding cause of his injury.

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