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Spino v. John S. Tilley Ladder Co.

696 A.2d 1169 (1997)

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Spino v. John S. Tilley Ladder Co.

Pennsylvania Supreme Court

696 A.2d 1169 (1997)

Facts

Louise Spino (plaintiff) was standing on a Type III ladder manufactured by John S. Tilley Ladder Company (Tilley) (defendant) when one of the ladder’s legs split, causing Spino to fall and break her leg. Spino sued Tilley, arguing that the ladder’s design was defective and that all Tilley’s Type III ladders shared this flaw. Tilley rebutted this claim by stating that it had no knowledge of any accidents or defect claims involving a split leg on any of the approximately 100,000 Type III ladders Tilley had sold during the last 100 years. Before trial, Spino asked the court to prevent Tilley’s president from testifying about the lack of prior leg-split claims. Tilley showed the court a log it had kept of all problem reports and claims that Tilley had received from any source and pointed out that there were no entries for a leg split on Type III ladders. The court determined that the log was a reliable source of prior claims and admitted Tilley’s testimony about no prior leg-split claims at trial. The jury found that the ladder did not have a defect, and Spino’s claim was dismissed. An intermediate court affirmed the dismissal, and Spino appealed the evidentiary ruling to the Pennsylvania Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Nigro, J.)

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