Summary
The Alabama Supreme Court considered whether summary judgment was properly entered for the manufacturer, lessor/supplier, and employer in a farm-machinery injury case. The court held that expert testimony created genuine issues of material fact regarding the Super Packer’s design, warnings, instructions, and the plaintiff’s appreciation of the danger. It reversed and remanded the summary judgments in favor of Harrell Company and Brooks AG.
Topics
Practice areas
Questions Presented
- Whether summary judgment was proper on Mathis's claims that the Super Packer was defectively designed and inadequately warned or instructed.
- Whether the evidence established contributory negligence as a matter of law.
- Whether Brooks AG could avoid liability under the Alabama Extended Manufacturers' Liability Doctrine by asserting that it was merely the supplier or lessor of the Super Packer.
- Whether substantial evidence created a jury question under the Employer's Liability Act concerning a defect in the machinery, Askew's negligence, proximate causation, and Mathis's contributory negligence.
Holdings
- Summary judgment was improper because Mathis presented substantial evidence creating genuine issues of material fact as to whether the Super Packer was unreasonably dangerous or defective in its design and whether its warnings and instructions were inadequate.
- The evidence did not establish contributory negligence as a matter of law because a jury could find that Mathis did not consciously appreciate the danger that the tramper cylinder would free-fall or that the metal bar would impale him.
- Because Brooks AG was in the business of selling, leasing, or renting products such as the Super Packer, it could not obtain summary judgment merely by asserting that it was only the supplier or lessor.
- Summary judgment was improper for Askew because substantial evidence created jury questions concerning whether the Super Packer was defective, whether Askew was negligent within the meaning of the Employer's Liability Act, whether that negligence proximately caused Mathis's injuries, and whether Mathis was contributorily negligent.
Key quotations
“Our review of a summary judgment is de novo.” (255)
“Mere “heedlessness” is insufficient to warrant a finding of contributory negligence as a matter of law.” (261)
Factual background
Kenneth Mathis, an employee of Larry Askew, was injured while preparing a Super Packer Cotton Module Builder for transport. After being told to hurry and move to another field, Mathis attempted to manually release a hydraulic-cylinder latch with a metal bar; the tramper cylinder fell and a metal bar impaled his arm. Mathis presented expert evidence that the machine lacked an additional hydraulic safety device, had an inadequately guarded or positioned metal bar, and contained inadequate warnings and instructions. He also presented evidence that he had not received proper training or manuals and did not consciously appreciate that the tramper cylinder could free-fall when the latch was manually opened.
Procedural history
Kenneth and Betty Mathis sued Harrell Company, Larry Askew, and Brooks AG after Kenneth was injured while operating a Super Packer Cotton Module Builder. Betty was later dismissed as a plaintiff. The trial court granted summary judgment for Harrell Company and Askew based principally on lack of defect and contributory negligence, and later granted Brooks AG's summary-judgment motion on the same grounds and its status as a supplier or lessor. The Supreme Court of Alabama reversed and remanded.
Remand instructions
The cause was remanded to the trial court for further proceedings on Mathis's claims against Harrell Company, Brooks AG, and Askew.