Troja v. Black & Decker Manufacturing Co. case brief

Troja v. Black & Decker Manufacturing Co. case brief summary
488 A.2d 516 (1985)

CASE SYNOPSIS

Appellant consumer brought a strict liability personal injury action against appellee manufacturer after the consumer accidentally amputated his thumb while using a saw manufactured by the manufacturer. The Circuit Court for Anne Arundel County (Maryland) granted the manufacturer's motion for a directed verdict on the defective design claim and entered judgment for the manufacturer on the failure to warn claim. The consumer sought review.

CASE FACTS
The consumer contended that the absence of a safety feature that would have prevented the saw from running when the guard fence was not in place rendered the saw unreasonably dangerous, and that the warnings provided by the manufacturer were inadequate.

DISCUSSION

• The court found that the failure of the manufacturer to incorporate a safety system was not an inherently unreasonable risk because the consumer offered no evidence that his suggested safety feature was available at the time the saw was manufactured or that the cost of such a feature would not have been prohibitive to its manufacture. 
• The court held that in a strict liability case, evidence of subsequent remedial measures was not admissible to prove culpable conduct. 
• The court reasoned that in this instance the modification that the manufacturer had made and that the consumer sought to introduce had not been made until almost seven years after the allegedly defective saw was manufactured. 
• The court reasoned that this the disparity in time was too great and would have the potential to divert the jury from the question of whether the warnings were defective at the time that the saw was manufactured.

CONCLUSION
The court affirmed the judgment and ordered the consumer to pay costs.

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