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Keywords

plaintiffappealtrialaffidavitsummary judgmentcompliance

plaintiffnegligenceliabilityappealtrialsummary judgmentcompliance

Related Cases

Soproni v. Polygon Apartment Partners, 137 Wash.2d 319, 971 P.2d 500, Prod.Liab.Rep. (CCH) P 15,448

Facts

In 1993, 20-month-old Daniel Soproni fell from a second-story window of an apartment complex onto a concrete patio. The child had been playing on a bed near the window, which he could easily open. Despite warnings from his mother and her boyfriend, Daniel climbed onto the window ledge and leaned against the screen, which dislodged, causing him to fall and sustain serious injuries. The window, marketed as the 'Alpine 220,' was designed to meet various safety codes but lacked a locking mechanism to prevent small children from opening it.

The suit against Alpine had its genesis in 1993, when 20-month-old Daniel Soproni fell from a second story window of an apartment complex onto a concrete patio.

Issue

Did the Court of Appeals correctly affirm the trial court's conclusion that no material factual issue precluded entry of a summary judgment in favor of Alpine Windows regarding the negligent design of the window and the failure to provide warnings?

Rule

A product manufacturer is liable if the product is not reasonably safe as designed, which can be established through a risk-utility analysis or a consumer expectations test.

A product manufacturer is subject to liability to a claimant if the claimant's harm was proximately caused by the negligence of the manufacturer in that the product was not reasonably safe as designed.

Analysis

The court determined that while the window complied with safety codes, this compliance did not preclude the possibility of a design defect. The affidavits from experts indicated that feasible alternative designs existed that could have prevented the accident. The court emphasized that the determination of whether a product is unreasonably dangerous is a question for the trier of fact, and the evidence presented by the plaintiffs created a genuine issue of material fact.

In our view, the Court of Appeals placed too much emphasis on Alpine's compliance with codes and standards. Although, as we have noted above, we indicated in Falk that conformity with codes may satisfy consumer expectations, evidence of compliance with codes should not foreclose the plaintiffs' claims.

Conclusion

The Supreme Court reversed the Court of Appeals' decision in part, allowing the design defect claims to proceed to trial while affirming the dismissal of the failure to warn claims.

We conclude that although the Court of Appeals correctly affirmed the trial court's summary judgment dismissing the plaintiffs' claim for failure to warn, it erred in affirming the summary judgment insofar as it dismissed plaintiffs' design defect claim.

Who won?

The prevailing party was the plaintiffs in part, as the Supreme Court allowed the design defect claims to proceed, indicating that there were genuine issues of material fact regarding the safety of the window design.

The majority correctly holds Alpine Windows (Alpine) did not violate a duty to warn Daniel Soproni regarding the use of the window in this case.

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