Richter v. Limax International
United States Court of Appeals for the Tenth Circuit
45 F.3d 1464 (1995)
Dearmedia Richter (plaintiff) purchased a mini-trampoline manufactured by Limax International (Limax) (defendant) for the purpose of exercising, specifically jogging. However, over time Richter began to experience significant pain after using the product and was later diagnosed with having stress fractures in both of her ankles. Richter filed suit in federal district court against Limax, asserting claims of strict products liability and negligence for the company’s failure to provide an adequate warning. The box containing the mini-trampoline did have a sticker affixed that stated the product was only to be used as an exercise device and not for acrobatics or any springboard type activities. At trial, Richter provided expert testimony that simple tests conducted by Limax would have revealed that, based upon the design of the product, repetitive jogging by a consumer would have placed significant stress on the individual’s feet and lower legs. Limax conceded that it conducted no tests, but noted that Richter’s complaint of stress fractures was the first the company had heard of. In a special verdict, the jury found that the mini-trampoline was not defectively designed, yet concluded that Limax was liable under strict liability and negligence for its failure to warn. The jury awarded Richter damages over $450,000, reduced by Richter’s percentage of fault of 38 percent. The district court granted Limax’s motion for a judgment as a matter of law, concluding that Limax had no duty to warn because Richter had failed to prove that Limax had knowledge of the danger of stress fractures or that the danger was known in the state of the art. The district court further held that under Kansas law, Limax had no duty to warn about dangers it might have discovered by conducting reasonable tests on the product. Richter appealed.
Rule of Law
Holding and Reasoning (Lay, J.)
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