James Parish II, Individually and as Parent and Next Friend of James Parish III, a Minor Child v. Icon Health & Fitness, Inc. and Jumpking, Inc.

Summary

The Iowa Supreme Court affirmed summary judgment for Jumpking, Inc. in a product-liability action arising from a plaintiff’s quadriplegic injury while performing a somersault on a trampoline. The court held that the plaintiff failed to provide evidence of a reasonable alternative design or establish that the trampoline was manifestly unreasonable under the Restatement (Third) of Torts. The court also concluded that the warnings specifically addressing somersaults and flips were adequate.

Holdings

1. For common and widely distributed products such as trampolines, a plaintiff ordinarily must present evidence of a reasonable alternative design; Parish failed to generate a genuine issue of fact that the trampoline was so manifestly unreasonable that the exception applied.
2. The warnings were adequate as a matter of law because they specifically warned against attempting somersaults or flips, the conduct in which Parish was engaged when injured.
3. The court did not decide the open-and-obvious issue.

Questions Presented

1. Whether Parish generated a genuine issue of material fact on his design-defect claim despite offering no reasonable alternative design, under Iowa's adoption of section 2(b) of the Restatement (Third) of Torts: Products Liability.
2. Whether the trampoline and enclosure's warnings were inadequate despite warning specifically against the somersaulting activity that caused Parish's injury.
3. Whether the open-and-obvious defense applied to the design-defect claim.

Disposition

affirmed