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Nelson v. Sunbeam Products, Inc.

2022 WL 79838, 579 F. Supp. 3d 857 (2022)

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Nelson v. Sunbeam Products, Inc.

United States District Court for the Eastern District of Texas
2022 WL 79838, 579 F. Supp. 3d 857 (2022)

  • Written by Tiffany Hester, JD

Facts

Debra Nelson (plaintiff) fell in her bedroom, tipping over a space heater and landing on top of it. Nelson could not move for some time, and the heater’s grill caused third-degree burns. The warning label instructed users to avoid burns by keeping bare skin away from the grill. Nelson sued the manufacturer, Sunbeam Products (defendant), for strict products liability, alleging defective design. Nelson’s expert, Dr. McClellan, testified that the heater’s grill reached 275 degrees, causing third-degree burns in under one second; the safety switch turned off the heater if it tipped forward or backward but not in other directions; and Sunbeam’s competitors sold affordable and safe heaters with secondary grills and omnidirectional safety switches. McClellan prototyped and tested changes to Sunbeam’s design, adding a secondary grill and omnidirectional safety switch. The secondary grill reached 110 degrees, a safe touch temperature, and the omnidirectional switch turned off the heater when tipped in any direction. McClellan testified that with these changes, Sunbeam’s heater still heated the room in the same way and would cost 10 percent more. The jury found for Nelson. Sunbeam moved for judgment notwithstanding the verdict.

Rule of Law

Issue

Holding and Reasoning (Mazzant, J.)

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