DOES A MANUFACTURER’S DUTY TO WARN TAKE INTO CONSIDERATION SPECIAL KNOWLEDGE OF THE INTENDED USER?
Sometimes the black letter law passed by the legislature is unclear. The legislature can’t anticipate every possible fact scenario when they pass a law, so it lay to the courts to interpret the law and give guidance to what it means. This interpretation is called case law. When the court decides a certain meeting to the law it essentially answers a legal question. Lawyers and other courts then can rely on that ruling when they have a similar issue in their case. The following case answers the question above.
Eyster v. Borg-Warner Corp., 206 S.E.2d 702 (Ga. Ct. App. 1974).
This case addresses the following issue:
Does a manufacturer’s duty to warn take into consideration special knowledge of the intended user?
Manufacturers of products have a duty to warn about potential dangers posed by their products. Id. at 703. These warnings include non-obvious dangers and even foreseeable misuses. Id. This case dealt with what warnings are required when the product is intended for a specific trade, rather than the general public. Id. Ultimately, the court found that a manufacturer is permitted to take into account specialized knowledge of the product’s intended user when determining if a warning is necessary. Id. at 705-06.
Defendant manufactured heating and cooling units. Id. at 702. Plaintiff had such a unit installed in her home, but the unit ultimately caught fire, causing severe damage to Plaintiff’s home and injury to Plaintiff herself. Id. The fire was caused by the connection of aluminum wires to copper wires, something that the unit did not warn could cause fires. Id. at 703. Defendant alleged that no warning was necessary because it was common knowledge among those in both the HVAC and electrical trades that connecting such wires posed a risk of fire. Id.
The court noted that there is no duty “to warn of obvious common dangers connected with the use of a product.” Id. at 704. For example, warning that a knife is sharp would be unnecessary—the knife’s sharpness is what provides its usefulness. Id. The danger here, however, was not within the common knowledge of the public. Id. at 703. Defendant argued that the intended user of the heating and cooling units would not be exposed to this danger, though. Id. Instead, a professional would be relied upon to install the units, including attaching the wires. Id. at 704.
It was “commonly known to those in the trade” that connecting these two types of wires was dangerous and should never be done. Id. at 704-05. Further, the units were vended to these professionals, not to the general public. Id. at 705. Because there is no need to warn “members of a profession against generally known risks,” Defendant did not have any obligation to place a warning about the improper wire connections. Id. Thus, Plaintiff’s suit had to be dismissed because the warnings contained on the unit were sufficient. Id.