Trek Bicycle Corporation v. Miguelez: A Look at Failure to Warn in Florida

photo_796_20060111It 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.

On appeal, Trek argued that the trial court erred in not granting its motion for a directed verdict on the failure to warn claim. The Third District Court of Appeal concurred and reversed the trial court ruling and jury verdict. In opposing the motion for a directed verdict, the plaintiff contended that had a warning sticker been placed on the bicycle – the parties disputed whether a sticker was present at trial – he would not have purchased the bicycle or, as a result, sustained injuries. At trial, a plaintiff bears the burden of proving that a defendant’s alleged failure to warn was a substantial factor in the events leading to injury. The key issue on appeal was whether the defendants’ failure to warn about possible issues in the design of the carbon forks that could cause the front wheel to stop abruptly was the proximate cause of the plaintiff’s injuries.

Proximate cause focuses on “whether . . . the defendant’s conduct foreseeably and substantially caused the specific injury that actually occurred.” McCain v. Florida Power Corp., 593 So. 2d 500, 502 (Fla. 1992). “[H]arm is ‘proximate’  . . . if prudent human foresight would lead one to expect that similar harm is likely to be substantially caused by the specific act or omission in question.” Id. at 503. The Third District held that the theory of causation proffered by the plaintiff was too attenuated to establish causation. Indeed, the court focused on the fact that the real substantial cause of the bicycle failure was road debris. Although the design of the bicycle may have compounded the risks associated with road debris, the object getting lodged in the plaintiff’s wheel was the real substantial cause of the bicycle failure and the plaintiff’s injuries. As the Third District noted, “[t]o link a failure to warn of the potential of damaged carbon fiber to fail to Miguelez’s choice of bicycle, and, in turn, to an event that might occur to [one] using the equipment as intended, is stretching the concept of proximate legal causation too far.” Accordingly, the court reversed the jury verdict and remanded with the instruction to enter judgment in favor of Trek.

Although the debris may have been the real substantial factor in the plaintiff’s bicycle failure and fall, we should note that product design can exacerbate certain unavoidable risks. Indeed, perhaps the plaintiff in this action would have purchased a different bicycle had he known that the wheels of this bike were, as he alleged, more susceptible to debris-related failure. Those issues aside, this case is a clear demonstration that personal injury litigation is not a simple matter of trying to convince a jury of your peers. Instead, successfully bringing legal action takes navigating various pre-trial and trial motions as well as arguments related to possible appeals. Accordingly, someone considering bringing any form of negligence case should deeply consider enlisting the aid of competent and experienced counsel. The South Florida product liability attorneys at Frankl & Kominsky have many years of experience represented injured South Floridians in both state and federal courts and are ready to help you assess and assert your possible claim. If you have a possible claim and are interested in knowing more about your options, feel free to contact us for a complimentary case consultation.

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