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Halliday v. Sturm, Ruger & Co.

Maryland Court of Appeals
792 A.2d 1145 (Md. 2002)


Facts

Jordan Garris, age three, shot and killed himself while playing with his father’s handgun in June 1999. When Jordan’s father bought the gun, it came with a free safety course (which he declined), a safety manual with instructions for preventing harm to young children, and a lock box and padlock. Jordan’s father ignored these instructions and safety precautions, and left the gun under his mattress with a loaded magazine nearby. Jordan found the two pieces and was able to assemble them from watching television. He shot himself in the head. Jordan’s mother, Halliday (plaintiff) brought suit against Sturm Ruger & Co. (Sturm Ruger) (defendant), the manufacturer of the gun, seeking to hold the company liable for Jordan’s death on the ground that the gun was defectively designed. Specifically, Halliday argued the gun did not contain adequate safety precautions to prevent its use by young children. Additionally, she argued the gun could have feasibly been made safer by the addition of a childproof grip safety, but that Sturm Ruger was liable for defective design for failing to install this addition. Halliday presented statistics showing that over one thousand and six hundred children had been killed by handguns since 1979, and argued that the fact that children would handle the guns should have been reasonably foreseeable to Sturm Ruger. In making her case, Halliday argued that the court should apply a “risk-utility” analysis instead of a “consumer expectation” test and hold that the gun in question failed that preferred test because the risk of excluding child safety features outweighs the utility of that exclusion, and alternative safer designs could have been adopted economically. The trial court rejected this test and granted Sturm Ruger’s motion for summary judgment, and the appellate court affirmed. Halliday appealed.

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Holding and Reasoning (Wilner, J.)

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