Namundi v. Rocky's Ace Hardware, LLC

81 Mass. App. Ct. 665, 2012 WL 1449723
CourtMassachusetts Appeals Court
DecidedApril 30, 2012
DocketNo. 11-P-1027
StatusPublished

This text of 81 Mass. App. Ct. 665 (Namundi v. Rocky's Ace Hardware, LLC) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Namundi v. Rocky's Ace Hardware, LLC, 81 Mass. App. Ct. 665, 2012 WL 1449723 (Mass. Ct. App. 2012).

Opinion

Grainger, J.

Congress has sought to create a balance between a commercial duty to notify the public of dangers associated with the use of a product, and the individual’s responsibility to [666]*666exercise common sense. Here, the plaintiffs appeal from a directed verdict in favor of the defendants on a products liability “failure to warn” claim. They contend that the judge erred in ruling as a matter of law that the label on a can of paint stripper complied with the Federal Hazardous Substances Act (FHSA), 15 U.S.C. §§ 1261 et seq. (2006). We affirm.

Background. In reviewing a directed verdict for the defendants, we consider all evidence in the light most favorable to the nonmoving party. See Kattar v. Demoulas, 433 Mass. 1, 18 (2000), citing McAvoy v. Shufrin, 401 Mass. 593, 596 (1988). In any event, the material facts are undisputed. The plaintiffs, Gertrude Namundi and Geoffrey Kiwanuka, purchased a can of “Ace Liquid Stripper” (stripper) from defendant Rocky’s Ace Hardware, LLC. The product was manufactured by defendant W. M. Barr & Co., Inc. The front of the can carried the label seen here:

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As can be seen, the label had a warning printed on the bottom that had the words “DANGER!” and “POISON!” in large capital letters, illustrated with a skull and crossbones.3 Following the words “DANGER!” and “POISON!” the label also stated in still capitalized, but somewhat smaller, letters, “extremely FLAMMABLE. MAY BE FATAL OR CAUSE BLINDNESS IF SWALLOWED. vapor harmful, skin and eye irritant. Read other cautions and HEALTH HAZARD INFORMATION On back panel.”4

[667]*667The stripper was stored in the plaintiffs’ basement,5 ***5 and a flash fire erupted as vapors were ignited by the pilot light on the hot water heater. The plaintiffs, husband and wife, both of whom suffered severe burns in the blaze, complained that the stripper was improperly labeled, defective, and unreasonably dangerous.

The judge directed a verdict in favor of the defendants on the failure to warn claim, ruling that the label complied with the FHSA.6 The jury, so instructed, then found the defendants not liable on the plaintiffs’ remaining claim for design defect. The plaintiffs then moved for a new trial. In this consolidated appeal from the judgment on the underlying jury verdict and the denial of the motion for a new trial, the only issue presented by plaintiffs is the label’s compliance with the FHSA.

Discussion. 1. Standard of review FHSA compliance. In reviewing a ruling on a directed verdict, we ask “whether ‘anywhere in the evidence, from whatever source derived, any combination of circumstances could be found from which a reasonable inference could be drawn in favor of the plaintiff.’ ” Raunela v. Hertz Corp., 361 Mass. 341, 343 (1972), quoting from Kelly v. Railway Exp. Agency, Inc., 315 Mass. 301, 302 (1943). “[A]n appellate court has plenary power of de nova review of all questions of law, including questions of law involving statutory construction.” Martha’s Vineyard Land Bank [668]*668Commn. v. Assessors of W. Tisbury, 62 Mass. App. Ct. 25, 27 n.3 (2004) (citation omitted). The same rules of construction apply to both regulations and statutes. See Johnson v. Commissioner of Pub. Welfare, 414 Mass. 572, 578 (1993).

In the circumstances presented here, where neither the composition of the can’s contents nor the label’s appearance and wording is in dispute, we treat the compliance of the labeling under our interpretation of the FHSA and its enabling regulations as a pure question of law,7 and “[w]e review the judge’s rulings on questions of law de nova.” Trace Constr., Inc. v. Dana Barros Sports Complex, LLC, 459 Mass. 346, 351 (2011). “[Concerning Federal law, we give great deference to decisions of Federal courts if they seem persuasive.” Commonwealth v. Murphy, 448 Mass. 452, 462 (2007).

2. FHSA compliance, a. The use of the word “POISON.” The plaintiffs’ first argument on appeal is that the defendants violated Federal statutory and regulatory law in labeling the stripper, and by doing so misled the plaintiffs to believe that poison was the only hazard associated with use of the product. Specifically, the plaintiffs assert that because the word “POISON” was prominently placed at the beginning of the warning label, the plaintiffs were led to discount or dismiss the entire balance of the warning as simply an explanation of the product’s poisonous qualities and a list of precautions to be taken against poison. It is tempting to dismiss this argument out of hand as an undeniable departure from common usage or common sense, especially bearing in mind that a label for any product with more than one hazardous quality must, perforce, start somewhere.8 However, [669]*669the Federal regulatory scheme here is characteristically complex and therefore amenable to a large number of interpretations that, once raised, we have the duty to address.

The plaintiffs assert in essence that the label followed standards more stringent than those actually applicable to the product’s level of toxicity, thus disrupting the careful gradations of prominence for warnings of different perils established by the regulatory scheme. We, paradoxically therefore, examine certain requirements that may not apply to the stripper, but with which the label complied nonetheless.

(i) Capitalization of “POISON.” The plaintiffs complain that the label displayed the word “poison” as a “signal word”9 *9 and assert that the FHSA and its regulations do not allow “poison” to be displayed in that category. The practical effect of deeming a particular word to be a “signal word” is that it is required to be entirely capitalized. See 16 C.F.R. § 1500.121(c)(4) (2011).

This argument fails on three counts. First, the regulatory scheme is at best unclear whether “poison” is deemed to be a signal word. Compare 16 C.F.R. § 1500.129 (2011) (referring to substances “required to bear the signal word ‘poison’ ” [emphasis added]) with 16 C.F.R. § 1500.121(c)(4) (referring to “the word ‘poison’ if required instead of a signal word” [emphasis added]). Second, the word “POISON” is required to be entirely capitalized regardless of its classification. See ibid. (“the word ‘poison’ if required instead of a signal word . . . shall be in capital letters”). It is undisputed that the word “poison” is required on the label, because the stripper contains more than four percent methyl alcohol (methanol) by weight. See 16 C.F.R. § 1500.14(a)(4), (b)(4) (2011). Finally, there is no prohibition against capitalizing the word “poison,” regardless of its definition under these different regulatory provisions.

(ii)

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96 F. Supp. 2d 408 (D. New Jersey, 2000)
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945 N.E.2d 833 (Massachusetts Supreme Judicial Court, 2011)
Kelly v. Railway Express Agency, Inc.
52 N.E.2d 411 (Massachusetts Supreme Judicial Court, 1943)
Johnson v. Commissioner of Public Welfare
608 N.E.2d 1045 (Massachusetts Supreme Judicial Court, 1993)
Kattar v. Demoulas
433 Mass. 1 (Massachusetts Supreme Judicial Court, 2000)
Commonwealth v. Murphy
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Martha's Vineyard Land Bank Commission v. Board of Assessors
814 N.E.2d 1147 (Massachusetts Appeals Court, 2004)

Cite This Page — Counsel Stack

Bluebook (online)
81 Mass. App. Ct. 665, 2012 WL 1449723, Counsel Stack Legal Research, https://law.counselstack.com/opinion/namundi-v-rockys-ace-hardware-llc-massappct-2012.