Whitehead v. Dycho Co., Inc.
This products liability case involves Jo Ann Whitehead, who was severely injured in an explosion caused by naphtha, a chemical supplied by multiple defendants to her employer, Magnavox. Whitehead alleged strict liability, breach of warranty, and negligent failure to warn. The trial court granted summary judgment for the defendants, finding Magnavox a "sophisticated user" and "learned intermediary," and that Whitehead's product use was unforeseeable. The Court of Appeals reversed and remanded for trial. However, the Supreme Court reversed the Court of Appeals, affirming the trial court's summary judgment, concluding that the defendants had adequately warned Magnavox, and Magnavox's failure to warn its employees constituted an independent intervening act that broke the causal connection. The Supreme Court found no proximate causation between the defendants' alleged failure to warn and Whitehead's injuries.