Norton v. Snapper Power Equipment

806 F.2d 1545 (1987)

Quick Summary

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James L. Norton (plaintiff) sued Snapper Power Equipment (defendant) after suffering severe hand injuries from a lawnmower accident, claiming the product was defective due to lacking safety features. This case was brought before the United States Court of Appeals for the Eleventh Circuit after the trial judge overturned a jury verdict favoring Norton.

The dispute centered on whether the lawnmower was unreasonably dangerous without a ‘dead man’ control, and if this alleged defect led to Norton’s injuries. The appellate court found enough evidence to support the jury’s decision and reversed the lower court’s judgment, directing them to rule in favor of Norton.

Facts of the Case

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James L. Norton (plaintiff), the owner of a commercial lawn mowing business, experienced a traumatic accident while operating a Snapper riding lawnmower. Norton approached an incline and upon nearing the top, the mower began slipping backward, ultimately crashing into a creek. This event resulted in Norton’s hand being severely injured by the lawnmower blade, leading to the amputation of four fingers.

Norton asserted that the lawnmower was unreasonably dangerous due to its lack of a ‘dead man’ control or automatic blade stop device, which he believed would have prevented his injuries. The defendant in this case is Snapper Power Equipment (Snapper), a division of Fuqua Industries, Inc., which manufactured the lawnmower in question.

Procedural Posture and History

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  1. Norton initiated a lawsuit in Florida state court claiming negligence, breach of warranty, and strict liability due to an alleged defect in the lawnmower.
  2. Snapper removed the case to the Middle District of Florida.
  3. The district court dismissed Norton’s negligence and warranty claims but sent the strict liability claim to the jury.
  4. The jury returned a verdict favorable to Norton, but the trial judge entered judgment notwithstanding the verdict, overturning the jury’s decision.
  5. Norton appealed to the United States Court of Appeals for the Eleventh Circuit.

I.R.A.C. Format


Issue Icon

Whether the district court erred in granting a judgment notwithstanding the verdict to Snapper on Norton’s strict liability claim.

Rule of Law

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The rule of law in this case is based on strict liability under Section 402A of the Restatement (Second) of Torts, which holds manufacturers accountable for selling products in a defective condition that is unreasonably dangerous to users.

The product’s dangerousness is evaluated against factors such as its utility, availability of safer alternatives, and feasibility of minimizing danger without impairing the product’s functionality or making it prohibitively expensive.

Reasoning and Analysis

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The appellate court scrutinized whether sufficient evidence was presented to justify the jury’s verdict that the lawnmower was defective and whether this defect caused Norton’s injury. The court considered expert testimonies about the existence and feasibility of ‘dead man’ devices prior to 1981 and Snapper’s efforts to develop such technology.

Despite Snapper’s argument that no such advanced safety devices were feasibly available at the time, Norton’s experts provided evidence to the contrary. The appellate court also evaluated the causation link between the alleged defect and Norton’s injury.

Even though Norton could not specify how his injury occurred during the crash, the evidence suggested that a more effective ‘dead man’ control could have stopped the blades sooner, potentially preventing his injuries. The court found this circumstantial evidence sufficient to support a reasonable inference of causation.


Conclusion Icon

The appellate court reversed the district court’s judgment notwithstanding the verdict and remanded with instructions to enter judgment in favor of Norton.

Key Takeaways

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  1. The appellate court held that ‘dead man’ devices were technologically feasible and should have been considered in evaluating the lawnmower’s safety.
  2. Circumstantial evidence can suffice in establishing causation between a product defect and an injury when direct evidence is unavailable.
  3. The concept of strict liability applies even when there is no negligence or breach of warranty if a product is found to be unreasonably dangerous and defective.

Relevant FAQs of this case

What factors must be considered to determine if a product is unreasonably dangerous under strict liability?

To determine if a product is unreasonably dangerous under strict liability, courts consider factors such as the product’s expected use, its utility to the public, the availability of safer design alternatives, the manufacturer’s ability to foresee hazards, and the user’s ability to avoid harm by exercising care while using the product.

  • For example: In a case where a chainsaw manufacturer fails to include an essential safety guard that is standard across the industry, the court may find the product unreasonably dangerous due to the lack of this critical feature, even if used correctly.

How does evidence of feasible safer alternatives impact a strict liability case?

Evidence of feasible safer alternatives can significantly impact a strict liability case by showing that the manufacturer could have adopted a safer design that would have reduced or eliminated the risk of harm without impairing the functionality of the product or making it prohibitively expensive.

  • For example: If a car manufacturer chooses not to include an available and cost-effective anti-lock braking system that would prevent accidents in slippery conditions, this could be evidence of negligence in choosing an inferior design.

In what ways can circumstantial evidence be used to establish causation in product liability cases?

Circumstantial evidence can be used to establish causation in product liability cases by illustrating a logical sequence of events that reasonably leads to the conclusion that the defect was responsible for the injury. This indirect proof is often necessary when direct evidence is unavailable or insufficient.

  • For example: If several users of a particular electric blanket report overheating and subsequent burns in a similar pattern of usage, circumstantial evidence may point to a manufacturing defect causing these injuries.


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