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Anderson v. Dreis & Krump Manufacturing Corp.

Court of Appeals of Washington
739 P.2d 1177 (1987)


Facts

Comet Corporation (Comet) purchased a press manufactured by Dreis & Krump Manufacturing Corporation (Dreis) (defendant). The press was used for a variety of different purposes. The press was designed with two activation methods. The first was a two-button system that required the user to use both hands to operate the press. Because the system required two hands for activation, this method had an inherent safety feature, as a user could not run the press and put a hand in the point of operation at the same time. The second method of activation was a foot lever. This method had no similar safety feature. Comet modified the two-button system on its press so that the press could be operated using one button and only one hand. Steve Anderson (plaintiff), an employee of Comet, was using the press’s modified one-button activation system when he reached into the point of operation to remove debris. Anderson severely injured his hand. Anderson brought a design-defect suit against Dreis, claiming that Dreis should have placed safety guards at the point of operation. Dreis argued that Comet’s modification of the activation system was a superseding cause that shielded Dreis from liability. The trial court agreed and awarded summary judgment to Dreis. Anderson appealed.

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Issue

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Holding and Reasoning (Munson, J.)

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Dissent (Green, J.)

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