Webb v. Navistar International Transportation Corp.

692 A.2d 343 (1996)

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Nature of the Case

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Facts

P learned that some of his cows might be out of the pasture that night. He and his father got out their tractor, a 1978 Model 464 farm tractor manufactured by Navistar, and they proceeded down Route 207 with P standing on the draw bar and his father driving. The tractor was struck in the rear by a car driven by an allegedly intoxicated operator. P suffered serious injuries to his legs. P sued D, the driver of the car, and others. P alleged negligence, breach of warranty, and strict products liability. The case proceeded to trial against D solely on the products liability claim. Ps argued that the tractor was defectively designed because (1) it allowed operation of a white field light at highway speeds without provision for separate red tail lights, and (2) it failed to provide a safe passenger location so that P could have ridden on the tractor without exposure to injury. P contends that D also failed to provide adequate warnings of these dangers. The trial court directed a verdict in D's favor on both claims. On appeal, the court reversed as to whether the design of the field light was defective and whether the manufacturer's warning on its use was inadequate. The second trial focused on the lighting system of the tractor. It has a red taillight, two amber lights with road flashers, two red rear reflectors, a reflective slow-moving-vehicle triangle, and a white field light mounted on the left rear bumper. A cautionary decal on the left front fender directs operators to use the flashing amber lights at all times when on public roads. The light system is designed so that when the flashing amber lights are in use, the red taillight activates and the white field light does not work. At the time of the accident, the flashing amber lights and the taillight did not work, and the reflectors were missing. In addition, by riding on the draw bar, P blocked the view of the reflective triangle. The cautionary decal also warned against riding the tractor unless a seat or platform is provided and instructed the operator to 'keep others off.' The owner's manual for the tractor also provides warnings and instructions. The manual warns: 'No riders allowed.' It also contains an instruction not to use the white field light on the highway under the heading CAUTION! P testified that while traveling on the highway, he employed both the headlights and the rear field light. It had not occurred to him that operating the tractor on the highway at night with the rear field light on was a hazard. The drunk driver that collided with the tractor testified that he believed the white field light mounted on the left rear bumper was the headlight of an approaching 'one-eyed' car. P claimed the lighting system was defective because it allowed the tractor to be operated on highways with the field light illuminated, and that D failed to adequately warn consumers of the known risk of using the field light while operating the tractor on the highway. P got the verdict, and D appealed.