Jones v. Ryobi, Ltd

37 F.3d 423 (8th Cir. 1994)



To recover on a theory of strict liability for defective design under Missouri law, a plaintiff must prove she was injured as a direct result of a defect that existed when the product was sold. Plaintiff has the burden to show the product had not been modified to create a defect that could have proximately caused her injury. When a third party's modification makes a safe product unsafe, the seller is relieved of liability even if the modification is foreseeable.


The employee's hand was injured while working on a small printing press that was modified to remove a plastic guard, which prevented the operator from reaching into the moving parts to adjust the eject wheels, and an interlock switch, which automatically shut off the press if the guard was opened. The manufacturer and distributor contended that the modification absolved them of liability for the employee's injuries. The employee argued that the modification rule did not apply because the press was not safe even before the modification.


Is a press manufacturer liable for the injuries sustained by a user after he modified the press, despite his claim the press was unsafe even before modification?




The court held that the district court properly granted the motions for judgment as a matter of law because the employee failed to prove that the press was unreasonably dangerous when put to a reasonably anticipated use. The court held that although the manufacturer provided tools for general maintenance of the press that could also be used to remove the guard, this provision did not make the manufacturer responsible for the guard's removal. The court held that the district court did not abuse its discretion in denying the amendment to the complaint because the evidence presented did not show colorable grounds for the employee's negligence theory.

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