In Steuhl v. Home Therapy Equipment, Inc. , Maria Steuhl sued Home Therapy Equipment (HTE) and Invacare Corp. (IC) after she was injured while attempting to lower a hospital bed. (Steuhl supposedly heard a "crunching noise" and the unit "suddenly dropped flat," exacerbating her back injuries.)
IC was the bed's manufacturer, HTE owned and leased the equipment to Steuhl, while Louis Olivetto, the assembler, was an HTE employee.
When Olivetto returned to Steuhl's home to effect a repair, an improperly installed clevis and hitch pin was thought to be the cause of the problem. Steuhl later filed suit "alleging negligence against [HTE] and strict products liability, breach of warranty, and negligent design, manufacture and distribution against [IC]." (IC then sued HTE for "indemnification and defense.")
When the Columbia County Supreme Court denied the parties' requests for relief in their favor, they appealed to the Appellate Division, Third Department, which found IC free of liability. As far as the AD3 was concerned, the hospital bed didn't have a "manufacturing flaw," because it was "constructed according to [IC's] specifications and design." IC hadn't fail to warn "against latent dangers" because it didn't sell beds "directly to end users, but to dealers," and it was Olivetto's responsibility to properly install the clevis and hitch pin.
Because Olivetto knew of the dangers of an improperly installed pin, IC's failure to warn wasn't the cause of Steuhl's injury. Also, there was no "design defect" since the "bed was reasonably safe for its intended use. (And, finally, since HTE hadn't yet been found negligent, the AD3 was of the opinion it was premature to entertain IC's cross-claim for indemnification and defense.)
Did the AD3 put that one to bed?
To download a copy of the Appellate Division's decision, please use this link: Steuhl v. Home Therapy Equipment, Inc.