Debra Davidson v. Stanadyne, Inc.

718 F.2d 1334, 1983 U.S. App. LEXIS 15467
CourtCourt of Appeals for the Fifth Circuit
DecidedNovember 7, 1983
Docket82-1276
StatusPublished
Cited by48 cases

This text of 718 F.2d 1334 (Debra Davidson v. Stanadyne, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Debra Davidson v. Stanadyne, Inc., 718 F.2d 1334, 1983 U.S. App. LEXIS 15467 (5th Cir. 1983).

Opinion

GARWOOD, Circuit Judge:

In this Texas diversity case Debra Davidson (“Davidson”), plaintiff-appellant, appeals from a summary judgment rendered against her in her products liability action against Stanadyne, Inc. (“Stanadyne”), defendant-appellee. She claims damages from Stanadyne for severe burns she suffered in her bathtub and shower allegedly caused by the defective design of Stanadyne’s single-control bath and shower faucet. We reverse the granting of summary judgment and remand the case to the district court for further proceedings.

I.

The primary facts of this ease are for the most part not in dispute. The shower in Davidson’s apartment was equipped with a single-control bath/shower faucet designed and manufactured by Stanadyne. Faucets of its design have been used widely in this country and abroad. 1 With a single-control faucet, water flow is adjusted by pulling or pushing the control knob. Pulling increases the flow pressure and pushing decreases it. Water temperature is adjusted by turning the control knob to the left for hot and to the right for cold. The turning span of the knob between the full hot and full cold positions is 180 degrees.

On July 9,1980 Davidson stepped into the bathtub and shower in her apartment and adjusted the volume and water temperature to her satisfaction with the control knob while letting the water run through the bathtub faucet. She then pulled up the small valve used to divert the water to the shower head. At this point she was standing with her back to the water and had begun to shampoo her hair when she apparently suffered an epileptic seizure. Davidson’s next recollection is awakening one to two hours later in a tub full of very hot water. In her deposition she testified that “I think while I was having the seizure with my body thrashing around that the water *1337 got turned up higher.” 2 Davidson suffered extremely serious burns over most of her body, which have required months of hospitalization and therapy.

Davidson brought suit against Stanadyne in district court alleging that its faucet was “defective and unreasonably dangerous in that it was designed and constructed in such a way as to allow inadvertent flow of full hot water.” She also alleged that Stanadyne had been negligent and had breached an implied warranty that the faucet was “safe and suitable for the purpose of controlling water flow and temperature in a residential shower.” She sought a total of $1,877,000 in damages.

Stanadyne moved for summary judgment on the grounds that there was no genuine issue as to any material fact and that there was no design defect, breach of warranty or negligence on its part as a matter of law. It also urged that the affirmative defense of misuse was present as a matter of law.

In response Davidson argued that the question of whether the single-control faucet was unreasonably dangerous was one for the jury. She alleged that “[a] rotation of less than seventy degrees to the faucet control will completely cut off all flow of cold water and allow full flow of hot water. Therefore a glancing blow to the control can easily allow a flow of hot water.” 3 She also argued that a safety device known as a “scald guard,” which is marketed by the defendant and other manufacturers, would have prevented her injuries and that evidence that a manufacturer presently designs a safer product “furnishes an inference that a safer design was feasible and that the existing design is defective.” 4 She presented an affidavit from a manufacturer’s representative that such “scald guards” were marketed as a part of single-control tub and shower faucets, that with such devices “the faucet cannot be inadvertently turned to a scalding hot setting,” and that single-control faucets comparable to Stanadyne’s and without a “scald guard” were usually priced in a $25-to-$30 range, while those with “scald guards” were $5 to $6 higher.

The district court granted Stanadyne’s motion for summary judgment. 5 It found that “[t]he producing cause of Plaintiff’s injuries was her accidentally striking the faucet and thereby turning it to the full hot position.” The court held, however, that “[t]he fact that the faucet may be turned to the full hot position by a body striking it, does not make the faucet an unreasonably dangerous product.” Nor, the court held, was it made so by the lack of a “scald guard” which would have prevented plaintiff’s injury. The district court concluded that the “product was not defective in its design.” It did not consider the plaintiff’s breach of warranty or negligence claims or Stanadyne’s contention that the facts of this case demonstrated the defense of “misuse” as a matter of law.

II.

The principles governing recovery in a products liability case alleging defective de *1338 sign under Texas law have been recently summarized in Kindred v. Con/Chem, Inc., 644 S.W.2d 828 (Tex.App. — Corpus Christi 1982), rev’d on other grounds, 650 S.W.2d 61 (Tex.1983):

“As established in [Turner v. General Motors Corp., 584 S.W.2d 844 (Tex.1979) ], the predicate for recovery in a defective design case is a showing that the product was defective, that the defect made the product unreasonably dangerous and that the defect was a producing cause of injuries ....
“To prove that there is a defect in design which is unreasonably dangerous, a plaintiff must show that the likelihood and gravity of injury from its use exceeds its utility. Boatland of Houston, Inc. v. Bailey, 609 S.W.2d 743, 746 (Tex.1980). In making their decision, the jury may consider evidence of the economic and scientific feasibility of alternative designs, the usefulness and desirability of the product, the ability to eliminate the risk without seriously [decreasing the product’s usefulness or [increasing its] cost.” Id. at 830-31.

As we recently pointed out in Carter v. Massey-Ferguson, Inc., 716 F.2d 344 at 347 (5th Cir.1983), since Turner v. General Motors Corp., 584 S.W.2d 844 (Tex.1979), in strict liability products cases Texas has followed the rule that the ultimate test for defective design is whether the product is “unreasonably” dangerous in the sense that “the danger-in-fact associated with the use of the product outweighs the utility of the product.” Although ordinary consumer expectations may be relevant in making this determination, such expectations do not of themselves constitute the ultimate standard. Carter v. Massey-Ferguson, Inc.,

Related

Jones v. Orkin, LLC
E.D. Louisiana, 2024
Zelaya v. Walmart Inc
E.D. Louisiana, 2023
Woodson v. Waffle House, Inc.
E.D. Louisiana, 2022
Evans v. Lopinto
E.D. Louisiana, 2022
Dickerson v. Hapl
E.D. Louisiana, 2020
Kandice Pullen v. Caddo Parish School Board
830 F.3d 205 (Fifth Circuit, 2016)
Top Rank, Inc. v. Ortiz (In Re Ortiz)
400 B.R. 755 (C.D. California, 2009)
Coleman v. Cintas Sales Corp.
40 S.W.3d 544 (Court of Appeals of Texas, 2001)
Oser v. Wal-Mart Stores, Inc.
951 F. Supp. 115 (S.D. Texas, 1996)
Bennett v. PRC Public Sector, Inc.
931 F. Supp. 484 (S.D. Texas, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
718 F.2d 1334, 1983 U.S. App. LEXIS 15467, Counsel Stack Legal Research, https://law.counselstack.com/opinion/debra-davidson-v-stanadyne-inc-ca5-1983.