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Under Massachusetts law, warranty liability is a remedy intended to be fully as comprehensive as the strict liability theory of recovery of many other jurisdictions. Accordingly, manufacturers must design products so that they are fit for the ordinary purposes for which such goods are used. Mass. Gen. Laws ch. 106, § 2-314(2)(c). A product is reasonably fit for its purposes if the design prevents the reasonably foreseeable risks attending the product's use in that setting. Thus, Massachusetts law is congruent in nearly all respects with the principles expressed in the Restatement (Second) of Torts § 402A. A reasonably fit product need not be a risk-free product, however. Even where the product design creates a risk of foreseeable harm, the question is whether this risk was unreasonable.
Carlos Osorio ("Osorio") filed a diversity suit against One World Technologies, Inc. and Ryobi Technologies, Inc. (collectively, "Ryobi") in the United States District Court for the District of Massachusetts. The complaint alleged claims arising from a hand injury suffered in a construction site accident involving one of Ryobi's table saws. Ryobi argued that Osorio failed to meet a prima facie obligation to present a reasonable alternative design for the product at issue that accounted for the weight, cost, and other features particular to the saw. After an eight-day jury trial, the jury found for Osorio and awarded damages of $1.5 million. Ryobi then filed a motion for judgment as a matter of law and for a new trial, which the district court denied. Ryobi now appealed these decisions.
Did the Massachusetts law require a prima facie showing on reasonable alternative design for the product at issue that accounted for the weight, cost, and other features particular to the saw?
The court held that the record evidence was sufficient to permit the jury to make a reasoned determination and that Massachusetts law did not require a prima facie showing on reasonable alternative design for the product at issue that accounted for the weight, cost, and other features particular to the saw. It was the jury's province to determine whether the relevant factors, properly balanced, suggested that the saw's design was unreasonable. The increase in expense of a proposed alternative was but one of those factors and the jury was free to determine that the costs of such an alternative exceeded its benefits. Evidence relating to the mechanical feasibility or increased weight of an alternative design could be similarly balanced. Further, the court was not convinced that the suit reached into impermissible categorical liability. The evidence presented was sufficient to allow the case to reach the jury.