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Valk Manufacturing Company v. Rangaswamy

Court of Special Appeals of Maryland
537 A.2d 622 (1988)


Facts

Dr. Srinivasa Rangaswamy was struck by a dump truck while turning into an intersection. At the time, a hitch used for attaching a snowplow was mounted on the front of the truck. The hitch was manufactured by Valk Manufacturing Company (Valk) (defendant) and featured a steel arm that extended 29 inches beyond the front of the dump truck. During the collision, the arm of the hitch penetrated Dr. Rangaswamy’s vehicle, and he died shortly thereafter. Rangaswamy’s family (Rangaswamys) (plaintiffs) brought a wrongful-death suit against Valk, claiming that Valk was strictly liable in tort because the design of the snowplow hitch was defective. At trial, the Rangaswamys provided expert-witness testimony that the hitch design was unreasonably dangerous and that a quick-disconnect hose would have allowed for the hitch to be easily removed when the snowplow was not being used. The jury was given an instruction on the risk-utility test for assessing a design defect and returned a verdict in favor of the Rangaswamys. Valk appealed the decision.

Rule of Law

Issue

Holding and Reasoning (Moylan, J.)

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