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Torts Keyed to Epstein
Hood v. Ryobi American Corp
Facts
Plaintiff purchased a miter saw made by Ryobi (Defendant). Warnings were clearly posted on the saw, which indicated the user should operate the saw only when the blade guards are in place. The day after the purchase, Plaintiff began to use the saw but found that the blade guard prevented the blade from passing through a piece of wood that was four inches in height. Plaintiff removed the guards despite the warnings. The warnings were explicit but did not tell the operator why or how injury would occur if the guards were removed. With the guards removed, Plaintiff used the saw and was injured when the blade flew off the saw; Plaintiff’s thumb was partially amputated and his right leg was lacerated. Plaintiff admits that he read the owner’s manual and most of the warning labels before using the saw. He claims however that he believed the blade guards were intended solely to prevent a user’s clothing or fingers from coming into contact with the saw. Plaintiff contends that he was unaware that removing the guards would cause the spinning blade to detach from the saw. Plaintiff sued Defendant for products liability for failure to warn and defective design. The court entered summary judgment for Defendant finding that in the face of adequate warnings, Plaintiff altered the saw and caused his own injury. Plaintiff appealed.
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