Hakim v. Safariland, LLC

Safariland, LLC (defendant) manufactured 12-gauge shotgun rounds known as breaching rounds. They were designed to disintegrate upon contact with metal, allowing police officers to breach locked doors by firing a round at the metal hinges attaching a door to its frame. The round’s force would destroy the hinges, but because the round would disintegrate, there was no risk of harming anyone behind the door. Safariland’s product literature for the rounds warned that they were dangerous if not used correctly and instructed that they should be fired directly at the metal door attachment, not the area between the attachment and the door. Those areas were usually made of wood. However, the literature did not expressly warn that the rounds would not disintegrate upon hitting wood. In fact, there were some statements generically stating the rounds would disintegrate upon hitting a hard surface. The DuPage County Sheriff’s Office purchased rounds and used them in a training exercise for its SWAT team. Officer Andrew Alaniz attempted to use the rounds to shear the hinge off a basement door rather than shooting at the hinge directly. Alaniz’s third shot hit wood and, failing to disintegrate, went through the basement ceiling and seriously injured officer David Hakim (plaintiff) on the floor above. Hakim sued Safariland in federal court, asserting strict-products-liability claims under Illinois law based on the rounds’ alleged design and manufacturing defects and Safariland’s alleged failure to adequately warn of the rounds’ risks. A jury held in Safariland’s favor regarding design and manufacturing defects but held in Hakim’s favor on the failure-to-warn claim, awarding Hakim $7.5 million. Safariland appealed.