It is common knowledge that the manufacturer of a product may be held liable for injuries arising from that product’s faulty design or construction. However, many are unaware the manufacturer may, in certain circumstances, be held liable for certain risks its product poses, even if the risks fall short of being a design defect. The issue of when a manufacturer needs to provide warning to a consumer was recently addressed in Trek Bicycle Corporation v. Miguelez, a recent decision from Florida’s Third District Court of Appeals.
The plaintiff in this case was riding a bicycle manufactured by Trek Bicycle Corporation along the Rickenbacker Causeway in Miami when the bicycle abruptly stopped. As a result, the plaintiff was jolted onto the handlebars and then to the ground of the causeway. The plaintiff sustained various face, jaw, and shoulder injuries. An examination of the bicycle revealed that an object had become lodged in the front wheel. Consequently, the object had hit the back side of the front carbon fiber forks of the bike, which caused the wheel to stop abruptly. The plaintiff brought suit against Trek as well as the retailer from which he purchased the bike. He asserted various product liability claims, including defective manufacture and defective design of the carbon forks. In addition, he brought a negligence claim predicated on the defendants’ failure to warn about the characteristics of the carbon fiber that created an added risk of wheel stoppage. The trial court granted the defendants’ motion for a directed verdict on the product liability claims, but it declined to grant the motion for a directed verdict on the failure to warn claim. Following the conclusion of the trial, the jury returned a verdict in the plaintiff’s favor on the failure to warn claim. The jury only found Trek liable for failure to warn and awarded 800,000 dollars in damages.