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Hood v. Ryobi America Corp.

United States Court of Appeals, Fourth Circuit
181 F.3d 608 (4th. 1999)


Facts

Hood (plaintiff) purchased and used a saw manufactured by Ryobi America Corp. (Ryobi) (defendant). Despite at least seven clear, simple warnings not to do so in the manufacturer’s manual, Hood removed the blade guards from the saw and used it for home carpentry. The warnings stated that using the blade guards was necessary to avoid “severe injury” and “possible serious personal injury.” Hood lost part of his thumb and lacerated his leg due to an accident caused by using the saw without blade guards. The saw blade detached from the saw and struck Hood. He brought suit against Ryobi alleging the company failed to comply with its duty to warn because the warnings about using blade guards did not explain the consequences potentially resulting from failure to use the guards. He stated that he was unaware of dangers from the saw blade detaching from the saw, but that Ryobi was aware of this danger because it had previously occurred to other users. Additionally, Hood alleged Ryobi was negligent and the saw was defective. The trial court granted summary judgment for Ryobi, and Hood appealed.

Rule of Law

Issue

Holding and Reasoning (Wilkinson, C.J.)

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