Anderson v. Olmsted Utility Equipment

2 Ohio App. Unrep. 635
CourtOhio Court of Appeals
DecidedMarch 30, 1990
DocketCase No. 4047
StatusPublished

This text of 2 Ohio App. Unrep. 635 (Anderson v. Olmsted Utility Equipment) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. Olmsted Utility Equipment, 2 Ohio App. Unrep. 635 (Ohio Ct. App. 1990).

Opinion

WINTER, J.

David Anderson and Mark Carlson were employed as electrical linemen for the City of Niles. In order to perform their duties, the linemen employ trucks with a hydraulic aerial bucket lift shaped like an elbow. The elbow consists of two metal arm-like pieces connected at a joint. The linemen service the lines by standing in "buckets" which are located at the end of the upper arm. A hydraulic cylinder at the base provides the thrust needed to raise the buckets so that the linemen are able to reach the electrical devices to be serviced.

In 1974, the city purchased a utility truck from Holán Equipment Division through a supplier, Cerni Motor Sales. In 1984, the city decided to replace the truck which had between 60,000 and 70,000 miles on the vehicle and a rusted-out body.

The city solicited bids for the purchase of a new truck with a remanufactured hydraulic aerial bucket lift. The bidders included Olmsted Utility Company, Inc., ("Olmsted") a manufacturer of digger derricks, aerial devices and utility bodies, as well as a dealer of Holán aerial devices.

[636]*636The city subsequently awarded Olmsted the contract. As part of the contract terms, Olmsted provided the following specifications for the hydraulic elbow:

"The Holán 804 is to be a total remanufactured including 100% tear down, inspectionand rebuild. ***A11 replacementparts are to be original equipment parts. The City of Niles is interested in having this equipment rebuilt to 100% Holán specifications and safety. Alternate and substitute parts not approved in writing by Holán engineering ARE NOT ACCEPTABLE."

The contract also included the following warranty provided by Olmsted:

"8. WARRANTY: The Bidder, by executing this Contract, warrants that the 1985 Line Truck with Remounted Used Hyrdaulic Elbow shall be free from defects in materials and workmanship for a period of One (1) Year from the date of delivery, or until said vehicle has been driven 12,000 miles, whichever occurs earlier. ***This express warranty shall not be construed to waive or diminish any other warranties implied in fact or implied in law, or any other right or remedies of the City."

By early September 1985, Olmsted provided the city with a new 1985 line truck which included the remanufactured hydraulic aerial bucket lift furnished as part of the trade-in by the City of Niles.

On September 18, 1985, Anderson and Carlson used the new truck to transfer wires from an old utility pole to a new one. While both men stood in the buckets at a height of twenty-five to thirty feet, the entire elbow dropped and caused the buckets to strike the ground. Both men suffered injuries as a consequence of the fall.

Inspections after the accident revealed that the lower arm hyraulic cylinder had failed.

On April 30, 1986, Anderson, his wife Charlene, and Carlson (appellees) filed suit for personal injuries against appellant Olmsted Utility Company, Inc. and Holán Equipment Division. Appellees alleged that Holán, as manufacturer and seller of the defective aerial bucket lift, breached its express and implied warranties. Appellees also alleged that Olmsted serviced and remanufactured the aerial bucket lift and had breached express and implied warranties. Appellees further alleged that both Holán and Olmsted had been negligent.

On May 4,1987, Holán moved for summary judgment on the ground that it was a successor corporation to the manufacturer of the aerial bucket lift and thus could not be held liable for any defect in the failed cylinder that caused appellees' injuries. On May 14, 1987, the court granted Holan's motion and dismissed Holán from the case.1 Appellees then filed an amended complaint naming only appellant as a defendant. The new complaint contained an additional allegation that appellant had remanufactured the failed cylinder and was strictly liable for appellees' injuries. On May 12, 1987, appellant filed a third-party complaint against Ohio Brass Division, Harvey Hubbell Corporation, Universal Hydraulics, Inc. and Regal Tube Company. Ohio Brass was the manufacturer's parent, Regal Tube manufactured the cylinder tube that ruptured, and Universal Hydraulics supplied the cylinder to the manufacturer.

The third-party defendants moved to dismiss appellant's third-party complaint on the grounds that they could not be held liable because appellant had "remanufactured" the hyrdaulic aerial bucket lift. The court granted these motions to dismiss.

Appellant moved for a directed verdict on the strict liability and express warranty claims. The trial court denied these motions and granted appellees' motion to withdraw their negligence claims. The case went to the jury on theories of strict liability and breach of express warranty.

The jury found in favor of appellees: David Anderson for $324,675; Charlene Anderson for $36,075; and Mark Carlson for $93,750.

The jury also answered four special interrogatories as follows:

"1. Did the defendant sell the aerial device to the City of Niles?

Answer: No;

"2. Did the Defendant remanufacture or rebuild the aerial device for the City of Niles?

Answer: Yes;

"3. Did the Defendant breach its express warranty to the City of Niles?

Answer: Yes; and

"4. If the answer (to Question Number Three) is yes, in what respects did the Defendant breach its express warranty?

Answer: Based on our examination of the evidence, we find that the aerial device was not free of defects in material and that these defects were the proximate cause of the equipment failure."

On March 24, 1988, appellant timely filed a notice of appeal and assigns the following as error:

[637]*637"1. The trial court erred in failing to grant defendant-appellant's motion for a directed verdict on Counts 2 and 6 of plaintiffs-appellees' amended complaint.

"2. The trial court erred in failing to grant defendant-appellant's motion for a directed verdict on Counts 1 and 5 of plaintiffs-appellees' amended complaint.

"3. The trial court erred in granting the motions of third-party defendants Regal Tube and the Ohio Brass Division of Harvey Hubbell Corp. to dismiss defendant-appellant's amended third-party complaint.

"4. The trial court erred in excluding opinion testimony of defense witnesses."

In its first assignment of error, appellant argues that the court erred in denying its motion for a directed verdict on the strict liability and breach of implied warranty counts. Appellant claims that it did not sell or manufacture the defective hydraulic elbow. Rather, appellant merely repaired and refurbished the elbow. Since appellant claims it is not a seller or manufacturer, appellant contends that the trial court erred in not dismissing the strict liability claim.

In this assignment, the determinative issue is whether appellant fits within the definition of "manufacturer" and is thereby liable under the theories of strict liability and breach of implied warranty. Through special interrogatories, the jury found that appellant did not sell the aerial device but did remanufacture or rebuild the aerial device.

In Temple v. Wean United, Inc. (1977), 50 Ohio St. 2d 317, the Ohio Supreme Court adopted Section 402A of the Restatement of Torts (2d) as its law on strict liability.

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Bluebook (online)
2 Ohio App. Unrep. 635, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-olmsted-utility-equipment-ohioctapp-1990.