Kellar v. Inductotherm Corp.
Plaintiffs James D. Kellar, a foundry worker, and his wife, filed a products liability action against the manufacturer of a channel furnace. Kellar was injured when he was struck by scrap metal, became dazed, and fell into an unguarded pit surrounding the furnace at Vestal Manufacturing Company, his employer. The furnace was sold to Vestal in 1971, and Vestal installed it with platforms, creating the pit. Vestal also attached a rear deck from the defendant, which partially covered the pit when the furnace was horizontal. Plaintiffs argued the furnace was defective and unreasonably dangerous due to the lack of a guard for the pit and a failure to warn. The defendant moved for judgment notwithstanding the verdict, arguing that the defect was in Vestal's installation, not their product, and that the danger was obvious. The court, applying Tennessee law, granted the defendant's motion, ruling that liability under Section 402A only applies if the manufacturer's product itself is defective and causes harm, and that the open pit was created by Vestal, not the defendant. Furthermore, the court found the danger of the unguarded pit was obvious to the plaintiff.