Lynch v. Athey Products Corp.

Summary

The Delaware Superior Court considered a manufacturer's motion for summary judgment in a products-liability action arising from injuries caused by a conveyor guard door. The court addressed the sufficiency of the plaintiff's expert affidavit under Superior Court Civil Rule 56(e), concluding that it contained conclusory allegations unsupported by specific facts. The court also examined whether the defendant's expert affidavit established the absence of genuine issues concerning negligent design, manufacture, warnings, and causation.

Holdings

1. An expert affidavit opposing summary judgment must contain admissible opinion evidence supported by specific facts and data; conclusory opinions that merely restate the pleadings and lack a factual foundation are insufficient and may be stricken when timely objected to.
2. A movant generally cannot obtain summary judgment on negligent-design, negligent-manufacture, warning, or warranty issues merely by submitting an expert affidavit that is subject to evaluation by the fact finder, particularly where the testimony is not unequivocal, uncontradicted, and unimpeached.
3. A manufacturer's negligence is not defeated by a third party's negligence unless the third party's negligence was the sole proximate cause of the accident.

Questions Presented

1. Whether the plaintiff's expert affidavit satisfied Delaware Superior Court Civil Rule 56(e) by presenting admissible opinion testimony based on specific supporting facts.
2. Whether the defendant's expert affidavit established the absence of genuine issues of material fact concerning negligent design, negligent manufacture, warnings, and warranty claims.
3. Whether summary judgment was appropriate where the material issues involved conflicting expert opinions, causation, credibility, and the adequacy of the conveyor's design and warnings.