prod.liab.rep. (Cch) P 14,309 Robert Eugene Henry, Tonya Renee Henry v. General Motors Corporation

60 F.3d 1545, 1995 U.S. App. LEXIS 22515
CourtCourt of Appeals for the Eleventh Circuit
DecidedAugust 16, 1995
Docket93-9458, 94-8028
StatusPublished
Cited by6 cases

This text of 60 F.3d 1545 (prod.liab.rep. (Cch) P 14,309 Robert Eugene Henry, Tonya Renee Henry v. General Motors Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
prod.liab.rep. (Cch) P 14,309 Robert Eugene Henry, Tonya Renee Henry v. General Motors Corporation, 60 F.3d 1545, 1995 U.S. App. LEXIS 22515 (11th Cir. 1995).

Opinions

PER CURIAM:

Robert Eugene Henry sued General Motors Corporation (GM), asserting several product liability claims. A jury found in favor of GM, and Henry appeals. He contends that the district court erred in granting GM’s pretrial motion for summary judgment on his negligent-failure-to-warn and negligent-failure-to-instruct claims. Henry also contends that the district court erred in evi-dentiary rulings and in instructing the jury at trial. Finding no error, we affirm.

I. Background

Henry became paraplegic when a General Motors pickup truck fell off a jack and struck his shoulders. Henry had jacked the truck up in order to replace the truck’s front brake pads. After removing the wheel, he set it beside the jacked-up truck to sit on as he put his head and shoulders into the wheel well to reach the pads. The truck came off the jack, and when it fell the edge of the wheel well struck his shoulders, causing a compression fracture of his lower spine.

The accident and injury may have occurred for at least two reasons. First, Henry used the wrong part of the jack to lift the truck. [1547]*1547GM jacks for this truck have two jacking points: a concavity on top of the jack, and a hook that extends from that concavity down the outside of the jack. On a two-wheel drive vehicle such as the one on which Henry was working, the concavity is designed to lift the rear axle, and the hook is designed to lift the front control arm. Henry improperly used the concavity to lift the front control arm. Second, Henry made himself vulnerable by putting his head and shoulders in the wheel well.

The jack carried a yellow sticker with four warnings. One warning advised the user not to get under a jack-lifted vehicle. The jack sticker did not explain the proper use of the two jacking points, but it warned the user to follow the jacking instructions. The jacking instructions provided under the hood and in the owner’s manual did not verbally refer to the jack’s concavity and hook. The illustrations accompanying the instructions did show the jack’s hook being used to lift the control. arm in front and the jack’s concavity to lift the rear axle. The illustrations were small, however, and they did not highlight the jacking points.

Henry is illiterate. Although he noticed the jack sticker and knew that the sticker’s yellow color signified a warning, he did not ask anyone to read it to him. Neither did he have someone read the owner’s manual or the jacking instructions placed on the underside of the truck’s hood, near the jack storage.

Henry sued GM on several theories. He alleged negligent design, manufacture, warnings, and instructions. He also asserted a strict liability claim. GM moved for summary judgment on the negligent-failure-to-warn and -instruct claims. GM contended that it had no duty to warn because the danger of the truck’s falling on a person beneath it was open and obvious. In the alternative, GM contended that even if it had a duty to warn of the danger that the truck might fall, Henry’s failure to read the warning sticker and owner’s manual, not GM’s failure to warn adequately, was the proximate cause of the accident. In response, Henry argued that the danger of using the wrong jacking point was not open and obvious. Henry contended further that his illiteracy distinguishes his case from cases in which the plaintiff neglected to read the warning.1

The district court granted GM’s motion for summary judgment on his negligent-failure-to-warn and negligent-failure-to-instruct claims. The case proceeded to trial on Henry’s strict liability claim, and the jury returned a verdict for GM. Henry appeals.

II. Issue and Standard of Review

Henry primarily asserts that the district court erroneously granted GM partial summary judgment based on the court’s conclusion that Henry’s failure to read any warning precluded recovery for negligent failure to warn.2 We review the district court’s granting of summary judgment de novo, applying the same standards as the district court. Georgia Power Co. v. International Bhd. of Elec. Workers, Local 84, 995 F.2d 1030, 1031 (11th Cir.1993), cert. denied, — U.S. -, 114 S.Ct. 1644, 128 L.Ed.2d 364 (1994).

III. Discussion

Summary judgment is proper when “the pleadings, depositions, answers to interroga[1548]*1548tories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” Fed.R.Civ.P. 56(c). “Rule 56(c) mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial.” Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S.Ct. 2548, 2552, 91 L.Ed.2d 265 (1986). Under Georgia law, to recover for negligence, a plaintiff must show “(1) a legal duty to conform to a standard of conduct raised by the law for the protection of others against unreasonable risks of harm; (2) a breach of this standard; (3) a legally attributable causal connection between the conduct and the resulting injury; and (4) some loss or damage flowing to the plaintiffs legally protected interest as a result of the alleged breach of the legal duty.” Bradley Ctr., Inc. v. Wessner, 250 Ga. 199, 296 S.E.2d 693, 695 (1982). The manufacturer can breach its duty to warn in two ways: (1)by failing “to take adequate measures to communicate the warning to the ultimate user,” or (2) by failing “to provide a warning that, if communicated, was adequate to apprise the user of the product’s potential risks.” Rhodes v. Interstate Battery Sys., 722 F.2d 1517, 1519 (11th Cir.1984).

GM has shown itself entitled to summary judgment. First, Henry’s deposition testimony negates the element of breach in a claim based on Rhodes’s first prong. Unlike the plaintiff in Rhodes, who never even saw the warning, Henry testified that he not only saw the yellow sticker on the jack, but knew that the sticker signified a warning. Thus, no fact dispute exists as to whether the warning was “eommunicated[d] to the ultimate user.” See id.

Second, Henry’s uncontroverted failure to examine the warning once he had noticed it negates the causation element of a claim based on Rhodes’s second prong. See id. Under Georgia law, a product user’s failure to read an allegedly negligent warning, not the warning itself, is considered the proximate cause of an injury resulting from product misuse. See, e.g., Powell v. Harsco Corp., 209 Ga.App. 348, 433 S.E.2d 608

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60 F.3d 1545, 1995 U.S. App. LEXIS 22515, Counsel Stack Legal Research, https://law.counselstack.com/opinion/prodliabrep-cch-p-14309-robert-eugene-henry-tonya-renee-henry-v-ca11-1995.