Lawson v. Honeywell International, Inc.

Summary

The Mississippi Supreme Court held that a mere designer of a product is not a “manufacturer” subject to liability under the Mississippi Products Liability Act. The court affirmed summary judgment for Honeywell on the MPLA claim but reversed summary judgment on the common-law negligence claim, holding that the MPLA does not preclude negligence claims against nonmanufacturing, nonselling product designers.

Holdings

1. A mere designer that does not manufacture or sell the product is not a manufacturer subject to liability under the MPLA. Because the plain and common meaning of manufacturer does not include a mere product designer, summary judgment on Lawson's MPLA claim was proper.
2. The MPLA does not preclude common-law negligence claims against a product designer who is neither a manufacturer nor a seller and therefore does not fall within the statute's scope. Summary judgment on Lawson's negligence claim was improper.

Questions Presented

1. Whether Honeywell qualified as a manufacturer under the Mississippi Products Liability Act for purposes of Lawson's statutory design-defect claim.
2. Whether the Mississippi Products Liability Act precluded Lawson's common-law negligence claim against Honeywell as an alleged nonmanufacturing and nonselling product designer.

Disposition

reversed_and_remanded