Tulkku v. MacKworth Rees, Division of Avis Industries, Inc.

257 N.W.2d 128, 76 Mich. App. 472, 1977 Mich. App. LEXIS 937
CourtMichigan Court of Appeals
DecidedJuly 6, 1977
DocketDocket 26312
StatusPublished
Cited by9 cases

This text of 257 N.W.2d 128 (Tulkku v. MacKworth Rees, Division of Avis Industries, Inc.) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tulkku v. MacKworth Rees, Division of Avis Industries, Inc., 257 N.W.2d 128, 76 Mich. App. 472, 1977 Mich. App. LEXIS 937 (Mich. Ct. App. 1977).

Opinions

R. M. Maher, J.

Plaintiff, while working at Chrysler Sterling Stamping Plant, lost a portion of his left hand in an industrial accident. He brought this action against defendants Mackworth Rees and Illinois Tool Works and, after a lengthy trial, the jury returned a verdict of no cause of action for both defendants. Plaintiff appeals.

When injured, plaintiff was one of two operators of a large press. A palm button assembly manufactured by defendant Mackworth Rees activated the press cycle. The assembly was designed to require each operator to press two palm buttons for the press to cycle. Incorporated in the assembly was a switch manufactured by defendant Illinois Tool Works. While plaintiff, with his right hand on a. palm button, reached across the press bed with his left hand to adjust a piece of metal stock, the press cycled and severed his hand. Post-accident investigation by Chrysler indicated a broken switch in the palm button assembly caused the unexpected cycle of the press.

Plaintiff alleged negligence in design by both defendants, negligence in the manufacture of the palm button assembly by defendant Mackworth Rees and breach of implied warranties by both defendants. Defendants countered with allegations of contributory negligence and abusive treatment of the palm button assemblies at the Chrysler plant.

[476]*476Plaintiff contends that several evidentiary rulings at trial require reversal of the judgment against him. He first argues that the court prevented him from introducing evidence that after his accident Chrysler changed the buttons and switches on the presses at the Sterling plant. This evidence, plaintiff claims, was relevant to show safer design.

In Denolf v Frank L Jursik Co, 395 Mich 661; 238 NW2d 1 (1976), the Supreme Court held that the rule excluding evidence of subsequent repairs is inapplicable when the repairs have been made by a third party not involved in the action.

"The rule is primarily grounded in the policy that owners would be discouraged from attempting repairs that might prevent future injury if they feared that evidence of such acts could be introduced against them. This policy consideration is absent in a case, such as this, where imposition of liability is not sought against the person taking the remedial action.” 395 Mich at 667.

While policy considerations do not prevent evidence of subsequent repairs by nonparties, the evidence must be relevant to the issues of the case. In Denolf, the trial court admitted evidence showing the addition of a simple safety device to the machinery that had injured plaintiff. This evidence was clearly relevant to show alternate design feasibility.

On a separate record, a maintenance electrician testified that in the six months following plaintiff’s accident Mackworth Rees buttons at the Sterling plant were replaced with Clark buttons using Square D switches. This evidence was relevant only if used as hearsay. The mere fact that buttons and switches were changed does not tend to show [477]*477that the replacements utilized different or better safety features. If, as plaintiff contends, the jury could infer an opinion on the part of Chrysler management about the relative safety of the several buttons and switches from testimony by an electrician that buttons and switches manufactured by defendants were replaced, then the evidence, although relevant, is hearsay. 2 Wigmore, Evidence (3d ed), § 267.

The hearsay aspect of subsequent repairs evidence is seldom discussed, because the policy against evidence of a party’s repairs usually settles the question of admissibility and also because, if introduced against a party, the admission exception to the hearsay rule is applicable. 2 Wigmore, Evidence (3d ed), §§ 267, 283; McCormick, Evidence (2d ed), § 275.

It was not error here to exclude evidence of the changeover in buttons and switches. The ruling below did not prevent plaintiff from introducing evidence comparing defendant’s products with others available. The jury heard testimony from the safety engineer at the Sterling plant on the safety features and accident histories of various buttons and switches.

Plaintiff is correct in his assertion that the court was in error in permitting defendants to call four Chrysler employees under the adverse party statute, MCLA 600.2161; MSA 27A.2161. Thompson v Essex Wire Co, 27 Mich App 516; 183 NW2d 818 (1970). The record does not disclose, however, any prejudice to plaintiff caused by this error and it cannot be a basis for reversal.

Plaintiff next appeals the ruling below to exclude a deposition exhibit. The exhibit, an intraoffice memo written by a Chrysler employee, summarized several meetings between Chrysler em[478]*478ployees and defendant Mackworth Rees employees held after plaintiffs accident. The memo disclosed that defendant Mackworth Rees offered to design and test new buttons for Chrysler. Plaintiff contends this evidence was relevant to the question of whether defendant Mackworth Rees or Chrysler had the responsibility to test the button assemblies that were involved in plaintiffs accident. In deciding this relevancy question against plaintiff, the trial court did not abuse its discretion. The slight tendency of this evidence to show that defendant Mackworth Rees had the obligation, several years before the meetings summarized in the memo, to test button assemblies must be weighed against the policy against admission of evidence of subsequent remedial measures by a defendant.

Plaintiff also argues that the court erred in refusing to give his requested charge on contributory negligence. Plaintiff requested that the court instruct that contributory negligence was not a defense to plaintiffs negligence action. Defendant objected, contending that plaintiffs failure to follow safety procedures available to him was negligent. The court gave the standard jury instructions on contributory negligence.

To support his position that the court’s instruction on contributory negligence was inappropriate, plaintiff relies solely on Funk v General Motors Corp, 392 Mich 91; 220 NW2d 641 (1974). In Funk, plaintiff was injured while working on steel beams without a harness, nets or other safety equipment. The Supreme Court wrote that contributory negligence is not a defense "if the trier of fact finds that the employer-defendant’s breach of a common-law duty to provide safety equipment is the cause in fact of plaintiffs injury”. 392 Mich at 114.

Our research has found two cases which have [479]*479held that when a worker is injured by a press not equipped with adequate safety devices, contributory negligence is not a defense to the worker’s negligence action. Relying, as did Funk, on Soronen v Olde Milford Inn, Inc, 46 NJ 582; 218 A2d 630 (1966), Bexiga v Havir Manufacturing Corp, 60 NJ 402; 290 A2d 281 (1972), concluded that the defense of contributory negligence was unavailable in a negligence action premised upon the failure to provide palm button assemblies on a press.

"The asserted negligence of plaintiff — placing his hand under the ram while at the same time depressing the foot pedal — was the very eventuality the safety devices were designed to guard against.

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Related

Thursby v. Reynolds Metals Co.
466 So. 2d 245 (District Court of Appeal of Florida, 1985)
Tulkku v. MacKworth Rees Division of Avis Industries, Inc.
300 N.W.2d 46 (Michigan Court of Appeals, 1980)
Stambaugh v. Chrysler Corp.
292 N.W.2d 510 (Michigan Court of Appeals, 1980)
Vincent v. Allen Bradley Co.
291 N.W.2d 66 (Michigan Court of Appeals, 1980)
Suter v. San Angelo Foundry & MacHine Company
406 A.2d 140 (Supreme Court of New Jersey, 1979)
Tulkku v. MacKworth Rees Division of Avis Industries, Inc
281 N.W.2d 291 (Michigan Supreme Court, 1979)
Rivers v. Ford Motor Co.
280 N.W.2d 875 (Michigan Court of Appeals, 1979)

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Bluebook (online)
257 N.W.2d 128, 76 Mich. App. 472, 1977 Mich. App. LEXIS 937, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tulkku-v-mackworth-rees-division-of-avis-industries-inc-michctapp-1977.