Cutting v. Yoke Industrial Corp

CourtDistrict Court, W.D. Washington
DecidedNovember 4, 2022
Docket3:20-cv-05346
StatusUnknown

This text of Cutting v. Yoke Industrial Corp (Cutting v. Yoke Industrial Corp) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cutting v. Yoke Industrial Corp, (W.D. Wash. 2022).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 NICHOLAS CUTTING and KATHRYN CASE NO. C20-5346 BHS-JRC 8 CUTTING, ORDER 9 Plaintiffs, v. 10 YOKE INDUSTRIAL CORP., et al., 11 Defendants. 12

13 This matter comes before the Court on United States Magistrate Judge J. Richard 14 Creatura’s Report and Recommendation (“R&R”), Dkt. 71, and the parties’ Objections to 15 the R&R, Dkts. 72, 73, 74. Plaintiff Nicholas Cutting1 fell off a roof in 2017, sustaining 16 injuries. He claims he was fastened to a rope lifeline system sold and manufactured by 17 Defendants. The lifeline failed to stop his fall. Cutting sued alleging that the product 18 lacked an appropriate warning, that the product featured a design defect, and that the 19 defect caused his fall. 20 21 1 Nicholas Cutting’s wife, Kathryn Cutting, is also a plaintiff in this case. The Court refers to 22 them in the singular as “Cutting” for clarity and consistency. 1 I. BACKGROUND 2 Defendant Yoke Industrial Corp. manufactures and sells various rope grabs—a

3 device designed to stop a user from falling down a rope to which he is attached. Dkt. 48 4 at 6. Defendant Werner Co. manufactures and sells various fall protection systems, some 5 of which include Yoke manufactured rope grabs. Id. Defendant Home Depot USA Inc., a 6 retailer, sells some of Werner’s products, including the one at issue in this case. Id. 7 In 2017, non-party Jeffrey Gerbing hired Cutting to build an RV garage. Dkt. 48 at 8 5. Cutting was to install roof sheathing on the garage and to perform that work, he

9 purchased a fall protection system, the UpGear K211201, from Home Depot. Id. at 6. 10 Werner designed and manufactured the UpGear and Yoke supplied the product’s rope 11 grab, model N-602. Id.; Dkt. 54 at 3. The UpGear is designed to be an “All-in-One” rope 12 lifeline system intended to prevent a “freefall.” Dkt. 48 at 6. While working on Gerbing’s 13 RV garage roof, Cutting slipped and fell. Id. at 8. He claims he was wearing the UpGear

14 at the time and that it failed to prevent his fall. Id. at 7–8. While he says he does not 15 specifically remember grabbing the rope grab during the fall, he claims that he was using 16 the UpGear as instructed, that he reached for the rope grab, and that the UpGear failed to 17 stop him from falling to the ground. See, e.g., Dkt. 49-1 (Cutting Dep.) at 123:20–124:6; 18 153:19–154:3 Cutting’s fall caused a spinal fracture requiring surgery. Dkt. 48 at 8.

19 Fall protection systems like the one Cutting used are designed with a rope 20 connected to an anchor. A rope grab is attached to the rope on one side and to a lanyard 21 on the other. Dkt. 48 at 7. The lanyard has a clip on the end and the user is hooked to the 22 lanyard clip with a snaphook. Id. The UpGear is shown in the pictures below. 1 LA ll. Product Descriptions 2 snaphook to anchor (alloy steel) ee Y ~ 3 iar 73 : / rope lifeline (polyester/polypropylene) /¥ Hdd Hy Le comma < | 5600 Ib minimum tensile strength 4 j Cee, Wee ne —_ Li | rope grab (alloy steel) ¢ | | on 1¢ po y lanyard (polyester) 5 \ ae Oe Ly) \ \ ee ( snaphook to harness (alloy steel) .

5 shock pack (polyester webbing, PVC protective sleeve)

g at 6. 9 Rope grabs can be manual or trailing. With manual rope grabs, the user can 10 || Squeeze the grab to move along the rope. /d. at 6. If the user falls, the manual rope grab 11 || locks in place on the rope in response to the user’s weight. /d. at 6-7. The UpGear is a 12 || manual rope grab. Dkt. 54 at 4. Trailing rope grabs trail the user and, when the grab is 13 || behind the user, the grab is in an open position which allows the user to move along the 14 ||rope without the grab locking. Dkt. 54 at 8. If the user falls, similar to the manual rope 15 || grab, the grab locks in place on the rope in response to the pull of the user’s weight. 16 || Trailing grabs now contain an “anti-panic” feature added in response to a known hazard 17 || called the “death grip.” /d. Around 2007-2010 the industry discovered that this hazard 18 || was present when a user fell while using a trailing rope grab and naturally responded by 19 || trying to grab onto the rope. /d. at 7-8. If the user grabbed the rope grab itself, the grab 20 || would remain open and fail to lock in place on the rope, resulting in a free fall. /d. at 8. 21 Defendants explain that one key difference between manual and trailing rope 22 || grabs is that, whereas trailing rope grabs are in an open position when the user is in front

1 of the grab, manual rope grabs are never open unless the user squeezes the grab in an 2 upward motion. Id. According to Defendants, for this reason, manual rope grabs do not

3 have the same “death grip” hazard as trailing rope grabs. Id. This frames a central factual 4 issue in this case: whether it is possible that Cutting grabbed the rope grab during his fall 5 and moved it into, or held it in, an open position, causing him to free fall to the ground. 6 While Cutting claims the UpGear’s failure caused him to fall and sustain injuries, 7 Defendants argue that Cutting’s version of events is impossible. Their experts opine that 8 one of three alternative factual scenarios must have actually taken place: (1) Cutting was

9 not wearing the UpGear at the time of his fall; (2) Cutting’s harness was not connected to 10 the lanyard at the time of his fall; or (3) Cutting left too much slack in the rope. Dkt. 54 at 11 18. Defendants believe that the most likely scenario is that Cutting was not wearing the 12 UpGear at the time of his fall. Id. Cutting argues he always wore the UpGear while 13 working on the roof and that he was wearing and using it properly at the time. Dkt. 61 at

14 6–7. He also points to other evidence, such as Gerbing’s statements that, every time he 15 saw Cutting working on the roof, Cutting was wearing the UpGear. Id. 16 Cutting sued Defendants2 alleging violations of Washington’s Product Liability 17 Act (“WPLA”), RCW 7.72.030–.040, negligence, and loss of consortium. Dkt. 1. Cutting 18 seeks general and special damages, costs and fees, prejudgment interest, and punitive and

19 exemplary damages. Id. at 11. 20

21 2 Cutting initially sued Werner and Home Depot under cause number 20-cv-5163 BHS. Shortly after, Cutting sued Yoke Industrial Corp. and Yoke, Inc., under the instant cause number. The parties 22 stipulated to consolidate the cases. Dkts. 25, 29. 1 The parties now all move for summary judgment, except Defendant Yoke Niagara. 2 Dkts. 48, 54, 55. Each side attacks the reliability of the others’ witnesses and claims that

3 without the opposing party’s expert witness testimony, no material issue of fact remains. 4 Werner and Home Depot also move to exclude Cutting’s expert witnesses, Joellen Gill 5 and Jeremy Bauer, Dkt. 56, and Cutting moves to strike defense expert witness David 6 Lough’s declaration and to strike defense expert witness Keith Schippers’ “three potential 7 scenario” theory, Dkt. 59 at 15–20.3 8 Judge Creatura denied Werner and Home Depot’s motion to exclude Bauer,

9 noting, however, that Bauer is not qualified to testify to ultimate conclusions of law. Dkt. 10 71 at 9. He denied in part and granted in part Werner and Home Depot’s motion to 11 exclude Gill, concluding that Werner and Home Depot challenged only Gill’s 12 qualifications to testify to the existence of a death grip hazard in the rope grab. Id. at 10. 13 He agreed Gill cannot testify to the existence of a hidden hazard but ruled that the rest of

14 her testimony is unchallenged and therefore admitted. Id. at 12. 15 The R&R denied Cutting’s motion to strike both defense experts’ testimony. Dkt. 16 71 at 12–15.

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Cutting v. Yoke Industrial Corp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cutting-v-yoke-industrial-corp-wawd-2022.