Hughes v. Magic Chef, Inc.
288 N.W.2d 542 (Iowa 1980)
- Hughes’ owned Magic Chef gas stove. When he refilled it, he didn’t relight all the pilot lights. Two days later Hughes was injured in a massive propane explosion caused by the leaking gas.
- Hughes sued Magic Chef for product liability.
- Magic Chef argued that Hughes had assumed the risk and was injured because he misused the product by not relighting the pilot lights. It wasn’t their fault that Hughes didn’t follow the instructions..
- Hughes argued that misuse is only a defense when the product is used in a manner the defendant could not reasonably foresee. But it was foreseeable that someone wouldn’t relight all three pilot lights.
- Misuse is generally for things that a manufacturer wouldn’t figure a reasonable person would do with their product. For example, if Hughes was using a propane tank for target practice, it would be misuse and Magic Chef couldn’t be held liable for not making the tank bullet-proof. However, refilling a tank and not relighting the pilot lights is the sort of thing you might reasonably expect to happen.
- Hughes also argued that assumption of risk is only a defense when the plaintiff voluntarily and unreasonably proceeded to encounter a known danger. Hughes didn’t know that the stove might explode.
- Assumption of risk is generally used for things like people who work on a bomb squad who are very aware that defusing bombs is dangerous. Most people would not say that refilling a BBQ grill was a ‘dangerous’ activity.
- The Trial Court found for Magic Chef. Hughes appealed.
- The Appellate Court affirmed. Hughes appealed.
- The Iowa Supreme Court reversed and ordered a new trial.
- The Iowa Supreme Court found that misuse is not an affirmative defense, instead it is a component of whether the accident was foreseeable.
- The Court said that the Trial Court erred because they asked the jury to consider what Hughes knew or ought to have known, but that’s irrelevant. The real question was what Magic Chef should have foreseen.
- On retrial, Hughes would have to prove that it was reasonably foreseeable that a pilot light might not be lit, and that the stove was unreasonably dangerous if a pilot light was left unlit. Hughes’ specific actions with regards to his stove are not relevant in a strict liability case such as this.
- Basically, this case said that if a person doesn’t follow the instructions, or makes a mistake in using the product, that doesn’t immunize the product manufacturer from product liability. If it is reasonably foreseeable that a person could make those mistakes when using the product, then the manufacturer is still liable.
- However, they would not be liable if the purchaser is doing crazy things with the product that a manufacturer couldn’t expect a reasonable person to do.