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Genie Industries, Inc. v. Matak

Supreme Court of Texas
462 S.W.3d 1 (2015)


Facts

Genie Industries, Inc. (defendant) manufactured and sold aerial lifts, platforms that raised workers so that they could reach high ceilings. One of Genie's lifts, the AWP-40S, was a lightweight lift with a small platform that raised 40 feet into the air. Because the base of the AWP-40S was small and the lift could potentially tip over, there were several stabilizing outriggers on the lift. The lift's platform could not be raised if any of the outriggers were out of place, but if the lift became destabilized while the platform was already in the air, the lift would continue to operate. Signs on the AWP-40S warned against releasing any of the outriggers while the platform was raised. A church in Beaumont, Texas hired an electric company to complete some work near the church ceiling and allowed two of the company's employees, James Boggan and Walter Matak, to use the church's AWP-40S for the project. Although Boggan and Matak used the AWP-40S correctly at first, they eventually began releasing the outriggers and moving the lift while Matak was still fully elevated on the platform. During one attempt to move the lift, it tipped over, and Matak was killed. Matak's estate (plaintiff) brought a wrongful-death action against Genie, alleging that a design defect in the AWP-40S caused the accident that killed Matak. At trial, the estate's expert testified about three safer alternative designs for the AWP-40S: (1) an automatic drop-down function, (2) a pothole-protection design, and (3) a chain-and-padlock feature. The estate's counsel suggested a block as an additional safer alternative design. A jury found for the estate, and the appellate court affirmed. The Texas Supreme Court granted Genie's petition for review.

Rule of Law

Issue

Holding and Reasoning (Hecht, C.J.)

Dissent (Boyd, J.)

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