Weigle v. SPX Corporation

Dist. Ct. erred in granting defendant-manufacturer’s motion for summary judgment in product liability action filed under Indiana law, alleging that defendant’s support stand used for truck repairs contained design defect. While Dist. Ct. could properly find that safety warnings provided by defendant were adequate since warnings adequately conveyed to user that failure to use support pin may result in personal injury, reasonable fact-finder could still find that instant support stand was unreasonably dangerous where: (1) design of support stand was unusual in relevant market; (2) instant stand was inherently unstable when support pin was not used, while other support stands had built-in safeguards to prevent stand from becoming unstable; and (3) defendant failed to present evidence that it undertook hazard-risk analysis on development of its support stand. Ct. rejected defendant’s contention that adequacy of safety warning was complete defense to any defective design claim.