Justia Products Liability Opinion Summaries

Articles Posted in Idaho Supreme Court - Civil
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Francisca Gomez died as the result of a horrific industrial accident that occurred while she was cleaning a seed sorting machine as part of her employment with the Crookham Company (“Crookham”). Her family (the Gomezes) received worker’s compensation benefits and also brought a wrongful death action. The Gomezes appealed a district court’s grant of summary judgment to Crookham on all claims relating to Mrs. Gomez’s death. The district court held that Mrs. Gomez was working within the scope of her employment at the time of the accident, that all of the Gomezes’ claims were barred by the exclusive remedy rule of Idaho worker’s compensation law, that the exception to the exclusive remedy rule provided by Idaho Code section 72-209(3) did not apply, and that the Gomezes’ product liability claims fail as a matter of law because Crookham is not a “manufacturer.” The Idaho Supreme Court determined that given the totality of the evidence in this case, which included prior OSHA violations for similar safety issues, the district court erred by failing to consider whether Crookham consciously disregarded information suggesting a significant risk to its employees working at or under the picking tables, which were neither locked nor tagged out, as they existed on the date of the accident. On this basis, the decision of the district court granting summary judgment to Crookham was reversed and the matter remanded for the trial court to apply the proper standard for proving an act of unprovoked physical aggression, and to determine whether there was a genuine issue of material fact as to whether Crookham consciously disregarded knowledge of a serious risk to Mrs. Gomez. View "Gomez v. Crookham" on Justia Law

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Francisca Gomez died as the result of a horrific industrial accident while she was cleaning a seed sorting machine as part of her employment with the Crookham Company (“Crookham”). Her family (the Gomezes) received worker’s compensation benefits and also brought a wrongful death action. The Gomezes appealed the district court's decision to grant Crookham’s motion for summary judgment on all claims relating to Mrs. Gomez’s death. The district court held that Mrs. Gomez was working within the scope of her employment at the time of the accident, that all of the Gomezes’ claims were barred by the exclusive remedy rule of Idaho worker’s compensation law, that the exception to the exclusive remedy rule provided by Idaho Code section 72-209(3) did not apply, and that the Gomezes’ product liability claims failed as a matter of law because Crookham was not a “manufacturer.” In affirming in part and reversing in part, the Idaho Supreme Court determined the trial court erred when it failed to consider whether Crookham committed an act of unprovoked physical aggression upon Mrs. Gomez by consciously disregarding knowledge that an injury would result. As such, the matter was remanded to the district court for further proceedings. View "Gomez v. Crookham" on Justia Law

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The family of Mrs. Francisca Gomez (the Gomezes) appealed a district court decision granting Crookham Company’s (Crookham) motion for summary judgment on all claims relating to Mrs. Gomez’s death. Crookham is a wholesale seed distributor located in Caldwell, Idaho. Mrs. Gomez was an employee of Crookham for more than thirty years before her death. In early 2015, Crookham decided that a new picking table was necessary to sort seeds more efficiently. A Crookham employee fabricated the new table and it was installed in the company’s “Scancore” room in late 2015. Although OSHA had previously cited Crookham for violating machine guard safety standards and lockout-tagout protocol with its former picking tables, the new picking table’s drive shaft was not fully guarded and Crookham did not perform the required lockout-tagout procedures while employees cleaned the table. While working in the Scanscore room, Mrs. Gomez was under the picking table attempting to clean it when the table’s exposed drive shaft caught her hair and pulled her into the machine. She died as a result of her injuries. OSHA subsequently investigated Crookham and issued “serious” violations to the company because it exposed its employees to the unguarded drive shaft without implementing lockout-tagout procedures. The district court held that Mrs. Gomez was working in the scope of her employment at the time of the accident, that all of the Gomezes’ claims were barred by the exclusive remedy rule of Idaho worker’s compensation law, that the exception to the exclusive remedy rule provided by Idaho Code section 72-209(3) did not apply, and that the Gomezes’ product liability claims fail as a matter of law because Crookham is not a “manufacturer.” Finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed. View "Gomez v. Crookham" on Justia Law