Oglesbee v. Glock

CourtCourt of Appeals for the Tenth Circuit
DecidedDecember 27, 2024
Docket23-5134
StatusUnpublished

This text of Oglesbee v. Glock (Oglesbee v. Glock) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oglesbee v. Glock, (10th Cir. 2024).

Opinion

Appellate Case: 23-5134 Document: 58-1 Date Filed: 12/27/2024 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT December 27, 2024 _________________________________ Christopher M. Wolpert Clerk of Court PATRICK OGLESBEE; KATHREN D. OGLESBEE,

Plaintiffs - Appellants,

v. No. 23-5134 (D.C. No. 4:18-CV-00560-GKF-CDL) GLOCK, INC., (N.D. Okla.)

Defendant - Appellee. _________________________________

ORDER AND JUDGMENT * _________________________________

Before MATHESON, McHUGH, and ROSSMAN, Circuit Judges. _________________________________

Patrick Oglesbee purchased a used Glock pistol that had been modified after it

left the possession and control of Glock, Inc. While providing firearm training, he

dropped the pistol, which fired when it hit the ground and shot him in the leg. With

his wife, Kathren Oglesbee, he sued Glock, alleging products liability, failure to

warn, and negligence.

* This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 23-5134 Document: 58-1 Date Filed: 12/27/2024 Page: 2

Applying Oklahoma law, the district court granted summary judgment for

Glock on all claims, holding that the pistol was not unreasonably dangerous because

Glock provided adequate warnings about the risk of using a modified pistol. The

Oglesbees appealed.

Exercising jurisdiction under 28 U.S.C. § 1291, we affirm.

I. BACKGROUND

A. Factual History 1

The Drop Fire Incident

Mr. Oglesbee, a certified firearms instructor, has “extensive firearms

experience with hundreds of hours of training on various weapons systems.” App.,

Vol. I at 86; App., Vol. II at 476. While providing a firearm training, he attempted to

holster the modified Glock pistol, but it fell to the ground and fired, shooting him in

the leg. Mr. Oglesbee lost his leg from this “drop fire” incident. 2

The Pistol and Modifications

Glock pistols contain the “Glock Safe Action System,” which includes a

trigger safety, firing pin safety, and drop safety. The system automatically engages

after the pistol is fired to prevent unintentional discharges such as drop fires.

1 On appeal from summary judgment, “we examine the record and all reasonable inferences that might be drawn from it in the light most favorable to the non-moving party.” Pinkerton v. Colo. Dep’t of Transp., 563 F.3d 1052, 1058 (10th Cir. 2009) (quotations omitted). 2 A “drop fire” incident occurs “when a pistol is dropped or falls onto a surface and a round of ammunition is unintentionally discharged.” App., Vol. I at 82 n.2.

2 Appellate Case: 23-5134 Document: 58-1 Date Filed: 12/27/2024 Page: 3

Mr. Oglesbee purchased the pistol in 2012. The pistol had been modified with

“aftermarket” parts—a trigger spring, firing pin spring, firing pin safety spring, and

internal connector piece—that differed from the corresponding Glock factory parts. 3

The aftermarket trigger spring had more tension than its Glock counterpart. The

aftermarket firing pin spring and firing pin safety spring had less tension. This

combination of aftermarket parts prevented the trigger from returning to its fully

forward position after firing and from re-engaging the trigger safety. 4

The Warnings

Mr. Oglesbee received and reviewed the Glock Instructions for Use Manual for

his pistol. It contains multiple warnings about unintentional discharges from

modified pistols. The first warning straddles pages three and five:

WARNING:

GLOCK PISTOLS HAVE SEVERAL INTERNAL DESIGN FEATURES AND MECHANICAL SAFETIES, DESIGNED TO PREVENT AN ACCIDENTAL DISCHARGE SHOULD THE PISTOL BE DROPPED OR RECEIVE A SEVERE BLOW TO THE MUZZLE, FRONT, OR BACK OF THE PISTOL.

THEREFORE, EXTRA CARE AND STRICT ADHERENCE TO THE SAFETY INSTRUCTIONS AND OTHER INSTRUCTIONS CONTAINED IN THIS

3 Aftermarket parts for Glock pistols are made by other manufacturers. See App., Vol. II at 284, 286, 456. Thousands of aftermarket parts combinations can be used to modify Glock pistols. See id. at 278-79, 463-64. 4 Mr. Oglesbee also modified the pistol. But no party contends his modifications contributed to the drop fire.

3 Appellate Case: 23-5134 Document: 58-1 Date Filed: 12/27/2024 Page: 4

MANUAL BY THE GUN USER IS MANDATORY FOR MINIMIZING THE RISK OF ACCIDENTS.

. . . THE PROPER AND SAFE FUNCTION OF THIS PISTOL IS * * * *

BASED ON THE PREMISE THAT PARTS ARE NOT ALTERED OR MODIFIED, AND THAT THE PISTOL IS USED FOR ITS INTENDED PURPOSE.

App., Vol. I at 166-67. 5

The Manual also warns that an ineffective trigger safety may lead to an

unintentional discharge:

In case the trigger safety proves to be ineffective for any reason, DANGER of an unintentional discharge exists. THE WEAPON IS THEN TO BE IMMEDIATELY UNLOADED AND RESTRICTED FROM ANY FURTHER USE. MAKE SURE THAT YOUR WEAPON IS PROPERLY REPAIRED AND CHECKED BY GLOCK INC. AUTHORIZED PERSONNEL BEFORE USING IT AGAIN!

Id. at 167.

The Manual further warns that “disassembly by the user” beyond basic field

stripping to clean the gun “is neither required nor recommended, and should only be

performed by a GLOCK-certified armorer.” Id. at 186. 6 The Manual does not

As indicated by asterisks, the warning cuts off midsentence on page three of the 5

Manual and resumes on page five, the next page in English. 6 “Field stripping” is “user-level, partial disassembly of a firearm that is performed without tools to allow for routine cleaning and lubrication of the major components.” App., Vol. I at 93 n.10, 185-87; App., Vol. II at 480.

4 Appellate Case: 23-5134 Document: 58-1 Date Filed: 12/27/2024 Page: 5

provide instructions on how to remove and replace the trigger spring, firing pin

spring, firing pin safety spring, or the internal connector piece.

Testing Instructions

The Manual also contains instructions for inspecting the pistol and testing its

safety features. It states that when “[p]erformed at regular intervals,” the testing

instructions “can help to confirm that [the pistol] is functioning properly.” Id. at 188.

The Manual provides 13 testing instructions and states that “[f]ailure of any of the

following checks, which cannot be remedied by cleaning should be referred to

GLOCK, Inc., your local GLOCK dealer, or a GLOCK-certified Armorer.” Id.

The testing instructions warn that if the “firing pin safety fails to keep the

firing pin from moving forward” or if “the trigger safety fails to keep the trigger from

moving rearward and the pistol dry fires DO NOT LOAD OR FIRE YOUR GLOCK

PISTOL.” Id. These warnings emphasize that if the “trigger safety proves to be

ineffective for any reason, DANGER of an unintentional discharge exists.”

After he purchased the modified Glock and before the drop fire incident,

Mr. Oglesbee reviewed the testing instructions and performed number 10, the

“REASSEMBLY AND TRIGGER SAFETY CHECK”:

Reassemble the pistol. BE SURE THAT THE PISTOL IS UNLOADED, and cycle the slide to reset the trigger to the forward position.

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