Fifth Circuit Affirms Product Liability Verdict Against Elevator Manufacturer

Applying the Mississippi Products Liability Act, the Fifth Circuit affirmed a verdict in favor of plaintiffs against the manufacturer and installer of a residential cargo elevator on defective design and failure to warn claims.  Following a three-day bench trial, the district court found that the output shaft of the elevator’s gear sheared from metal fatigue caused by the misalignment of the elevator’s drum and gear, and that the misalignment could have been avoided by proper sizing.  The district court concluded that the manufacturer acted unreasonably in failing to obtain information about the dangers posed by improper sizing of the components it chose to incorporate in the elevator, noting a catalog published in 2002 by the manufacturer of the gear component that warned of this specific danger.  On appeal, the elevator manufacturer argued that the district court had created a novel legal duty on manufacturers to research the specifications of the components it incorporates into its designs, but the Fifth Circuit disagreed.  The Fifth Circuit found no reversible error in the district court’s analysis and emphasized the district court’s finding that even if the elevator manufacturer had not seen the 2002 catalog published by the gear manufacturer, it still should have exercised reasonable care to understand any dangers associated with this component.