Case Against Combine Manufacturer Withstands Summary Judgment; Plaintiff’s Inability to Recall Events Not Enough To Exclude Evidence
Plaintiff was seriously injured when he came into contact with a sheave near a combine’s gear shift lever while helping his grandfather operate a combine used to harvest soybeans. While the plaintiff could not recall the events of the day he was injured, and while his grandfather did not see the injury occur, the grandfather was allowed to testify that the plaintiff was moving in the direction of the combine’s gear shift lever when he contacted the sheave. The plaintiff was also able to testify that he had no operational reason to reach his hand into the area of the accident. Moreover, the plaintiff had two expert witnesses, who testified that the plaintiff’s injuries were consistent with accidental contact with the sheave and that a proper guard around the sheave would have prevented any unplanned contact while attempting to access the gear shift lever.
The defendant combine manufacturer moved to dismiss the case at summary judgment, arguing that because there was no witness regarding how the accident occurred, the plaintiff could not prove that a design defect (here, lack of protective guards) was the proximate cause of the plaintiff’s injuries rather than plaintiff’s own negligence. The defendant specifically highlighted that the plaintiff’s experts had not performed an accident reconstruction nor had they ruled out the possibility that the plaintiff intentionally reached into the area containing the sheave.
The U.S. District Court for the Eastern District of Pennsylvania rejected the defendant’s argument. Although the court recognized that where there is an absence of proof such that causation between the defect and injury is a “mere possibility,” the court concluded that the plaintiff’s evidence was sufficient to withstand summary judgment because “there [wa]s at least some evidence linking the defect to the plaintiff’s injuries.” The court reasoned where the plaintiff had been told to shift gears and testified he would have no operational reason to reach into the area containing the sheave, and where his experts testified that a proper guard would have prevented any unplanned contact, the plaintiff had provided evidence beyond mere speculation that was sufficient for a reasonable jury to find in the plaintiff’s favor. Accordingly, the court denied the defendants’ motion for summary judgment.
