Vautour v. Body Masters Sports Industries, Inc.

784 A.2d 1178 (2001)

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Nature of the Case

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Facts

Vautour (P) was injured while using a leg press machine manufactured by Body Masters (D). The press has two safety stops, both upper and lower. When the upper stops are disengaged, the lower stops are engaged and vice versa. A warning label on the machine cautions that the handles must be in a locked position when doing calf exercises (this engages the upper stops when performing calf raises). P got his injury when he moved his feet down to do calf raises. While aware of the warning label, P did not have the upper stops engaged. The sled and his knees fell toward his chest injuring his feet. P sued for strict liability, negligence, and breach of warranty; the location of the safety stops exposed users to an unreasonable risk of harm, and this design defect caused injuries. A biomechanics expert testified that the machine design was hazardous because it was not designed with adjustable stops. The expert also testified that he did not know of any manufacturer in the industry who made a machine using adjustable stops. The expert admitted that even adjustable stops would not reduce the risk of injury if the user failed to manually set them before operating the machine. D moved for a directed verdict or a dismissal. The trial court ruled that the area was one in which expert testimony was needed to establish the duty of care and that P’s expert failed to establish evidence sufficient to support a strict liability and negligence claims. The suit was dismissed. P appealed.