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Martin v. Ryobi Technologies Inc

United States District Court, D. Connecticut

March 22, 2018

ERIK MARTIN, Plaintiff,
RYOBI TECHNOLOGIES, INC., et al., Defendants.


          Jeffrey Alker Meyer United States District Judge.

         Plaintiff severely injured his hand on the blade of an electric table saw that he was using to cut pieces of wood. Plaintiff now seeks recovery from defendants, alleging that the design of the saw made it unreasonably dangerous. Defendants have moved for summary judgment. I will grant in part and deny in part their motion.


         The following undisputed facts are set forth in the light most favorable to plaintiff as the non-moving party. On August 1, 2014, plaintiff Erik Martin was cutting pieces of wood with a Ryobi BTS21 table saw at a job site in Glastonbury, Connecticut. He was using the saw to cut pieces of cedar wood down to one-inch shims. The saw was designed, manufactured, and distributed by defendant One World Technologies, Inc. (One World).[1]

         As plaintiff was pushing one of the wood pieces toward the blade, the wood caught an edge, and the blade began to slow down. Then the blade suddenly sucked the piece of wood quickly towards it-plaintiff's left hand was drawn as well into the blade, resulting in a severe injury.

         The saw that injured plaintiff was manufactured by One World in 2007. It is in the class of saws referred to as a bench top or table saw. It weighs 61.5 pounds without the stand and has a retail price of $249. It came equipped with a 3-in-1 blade guard assembly. The assembly included (1) a plastic basket that provides a physical barrier between the blade and the operator; (2) a splitter-spreader; and (3) anti-kickback pawls. The latter two elements reduce the likelihood of a “kickback” that could cause injury.

         When plaintiff was using the saw, the 3-in-1 blade guard that was supplied by One World to go with the saw was not attached. Someone else had removed it. As far as plaintiff knew, no blade guard was available for use on the saw.

         Plaintiff's evidence includes the expert testimony and report of Darry Robert Holt, a mechanical engineer with more than 40 years of experience evaluating the safety design of hundreds of machines and products of all types, including table saws. Plaintiff's expert opines that the saw was defective in design because it should have contained at least two superior safeguards to prevent the kind of injury that plaintiff suffered: something called “flesh detection technology” as well as a “modular” blade guard.

         Flesh detection technology first became available in 1999. With this technology, a blade is able to detect when it comes in contact with flesh. Upon sensing the flesh, the blade stops within a few milliseconds and drops below the table surface. The system reduces the severity of a blade contact injury from catastrophic to minimal. Currently, only one manufacturer- SawStop, LLC-makes saws with flesh detection technology. SawStop initially used this technology only for heavy duty “cabinet” saws that weigh hundreds of pounds and cost between $2, 000 and $3, 000. In 2014 it began to manufacture transportable table saws with flesh detection technology at a retail price of $1, 600.

         A modular blade guard provides more frontal protection from the blade when the hand approaches the blade from a fore/aft vector. In addition, the component parts of the blade guard can be individually removed by the user, and the guard includes a splitter that can be adjusted to minimize kickback occurrences even when other safeguard components are missing. The modular blade guard is more “user friendly” because it offers better visibility than the 3-in-1 blade guard.


         The principles governing the Court's review of a motion for summary judgment are well established. Summary judgment may be granted only if “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to a judgment as a matter of law.” Fed.R.Civ.P. 56(a). I must view the facts in the light most favorable to the party who opposes the motion for summary judgment and then decide if those facts would be enough-if eventually proved at trial-to allow a reasonable jury to decide the case in favor of the opposing party. My role at summary judgment is not to judge the credibility of witnesses or to resolve close contested issues but solely to decide if there are enough facts that remain in dispute to warrant a trial. See generally Tolan v. Cotton, 134 S.Ct. 1861, 1866 (2014) (per curiam); Pollard v. New York Methodist Hosp., 861 F.3d 374, 378 (2d Cir. 2017).

         The Connecticut Products Liability Act provides a common cause of action for claims alleging personal injury and certain other harms from the use of a commercial product. See Conn. Gen. Stat. § 52-572m; Moss v. Wyeth Inc., 872 F.Supp.2d 162, 165 (D. Conn. 2012). Among the various types of products liability claims that a plaintiff may pursue is a claim for design defect: a claim that a product by its very design is unreasonably dangerous to a user or consumer. See Bifolck v. Philip Morris, Inc., 324 Conn. 402, 434 (2016). All such claims for a design defect require a plaintiff to prove five basic elements: (1) that the defendant designed the product at issue; (2) that the product as designed was defective (i.e., that it was unreasonably dangerous to the consumer or user); (3) that the defect caused plaintiff's injury; (4) that the defect existed at the time of design; and (5) that the product was expected to and did reach the consumer or user without substantial change in condition from the manner in which it was designed. See ibid.

         How does a court decide if a product is “unreasonably dangerous” in its design? Connecticut courts ordinarily apply a “risk-utility” test. Ibid. The risk-utility test focuses on whether a reasonable alternative design was feasible and available that would have avoided or reduced the risk of harm, such that the designer's failure to use that alternative design rendered the product unreasonably dangerous. Id. at 434-35. Among the factors to consider when deciding if an alternative design was feasible include: (1) the degree to which the alternative design could have reduced the product's danger without unreasonably increasing its costs; (2) the degree to which the alternative design could have been deployed without unreasonably impairing the product's usefulness, ...

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