Hood v. Ryobi America Corporation

181 F.3d 608 (4th Cir. 1999)

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Nature of the Case

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Facts

Hood (P) purchased a miter saw made by Ryobi (D). Warnings were clearly posted on the saw that indicated the user should operate the saw only with the blade guards in place. The day after the purchase P began to use the saw but found that the blade guard prevented the blade from passing through a piece of wood that was four inches in height. P then removed the guards despite his express knowledge of the warnings that indicated the saw should not be operated in such a fashion. The warnings were explicit but did not tell the operator as to why or how injury would occur if the guards were removed. With the guards removed, P used the saw and was injured when the blade flew off the saw; P's thumb was partially amputated, and his right leg was lacerated. P admits that he read the owner's manual and most of the warning labels before using the saw. P contends that he was unaware that removing the guards would cause the spinning blade to detach but that he thought the guards were for not having things get caught in the saw when operated. P sued and raised claims of a failure to warn and defective design. The court entered summary judgment for D finding that in the face of adequate warnings, P altered the saw and caused his own injury. The court stated that strict liability was conditioned upon the product reaching the user without substantial change in the condition in which it was sold and that a manufacturer was not liable in negligence if an intervening alteration of the product was the superseding cause of injury. P appealed.