Huffman v. Caterpillar Tractor Co.

Garry Huffman installed snowmaking equipment for a Colorado ski resort using a Caterpillar 561D pipelayer (pipelayer) manufactured by Caterpillar Tractor Company (Caterpillar) (defendant). Using the pipelayer, Garry would lay pipes into trenches located on the steep sides of ski slopes. One day, while Garry was laying pipes, he turned off the pipelayer’s engine, which deactivated the pipelayer’s hydraulic brakes. The pipelayer started to slide down the hill. The mechanical brakes, which were the only brakes available with the engine off, could not stop the pipelayer. Garry was crushed to death after he attempted to jump out of the runaway pipelayer. Pipelayers manufactured after the one used by Garry contained spring-applied emergency braking systems that could be used even if the engine was off. Garry’s wife, Susan Huffman (plaintiff), filed a product-liability action against Caterpillar, arguing that the pipelayer was unreasonably dangerous because it was nearly impossible to stop with the mechanical brakes alone. Susan established that it was common practice for workers to turn off pipelayers while on ski slopes. Caterpillar moved to dismiss, arguing that Susan failed to state a claim that the pipelayer was dangerously defective. Caterpillar also raised a comparative-fault affirmative defense, arguing that Garry’s negligent misuse of the pipelayer had caused his death. The trial court denied Caterpillar’s motion to dismiss. The trial court also denied Susan’s request to instruct the jury that ordinary negligence could not be counted against Garry in the comparative-fault analysis. The jury ruled against Caterpillar but found that Garry was 50 percent at fault and reduced Susan’s damages accordingly. Susan and Caterpillar both appealed.