Products Liability Using the Risk-Benefit Test in Pennsylvania
To help understand and appreciate the steps required to develop and try a products case using the RBT, we provide this account of a recently litigated defectively designed helmet case.
April 06, 2023 at 10:37 AM
8 minute read
Consumers in Pennsylvania are entitled to bring suit for harm caused by a defectively designed product using one or both of these legal tests: "the consumer expectation test" (CET) or "the risk-benefit test" (RBT). Each test or definition of defect considered by a jury has its particular elements of proof and applying those elements to build your case can be daunting and expensive—because they are almost always expert witness dependent. To help understand and appreciate the steps required to develop and try a products case using the RBT, we provide this account of a recently litigated defectively designed helmet case.
The RBT provides that a product is in a defective condition if a "reasonable person" would conclude that the probability and seriousness of harm caused by the product (as sold) outweighs the burden or cost of taking precautions. This analysis accounts for the manufacturer's need to adopt precautions proportionate to the magnitude of the expected risk. The RBT provides for a post hoc opportunity to decide whether a manufacturer's conduct in manufacturing or designing a product was reasonable. This analysis is known as the "hindsight test." Courts applying the hindsight test note that a product is judged not by the conduct of the manufacturer or designer, but rather by the quality of the end result—the product is the focus of the inquiry. See Tincher v. Omega Flex, 104 A.3d 328, 391-403 (Pa. 2014). The quality of the product is measured not only by the information available to the manufacturer at the time of design, but also by the information available to the trier of fact at the time of trial. That test is articulated as follows: whether a reasonable manufacturer would continue to market his product in the same condition as he sold it to the plaintiff with knowledge of the likely dangerous consequences the trial has revealed. When a product manufacturer designs and markets some of its products with safety features which "… would probably protect … from serious injuries, it is itself strong evidence that the product … lacking such a device is defective …" Further, "this reflects the manufacturer's judgment that a vehicle … with the safety feature … will not be unduly expensive or inconvenient to use …" See Hammond v. International Harvester, 691 F.2d 646, 651 (3d Cir. 1982, PA law). If a defendant put a product that caused the plaintiff's harm into the stream of commerce and if that product was defective under one of the relevant rubrics, then the defendant is liable. See Roverano v. John Crane, 226 A.3d 526 (Pa. 2020).
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2025 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllOzempic Defendants Seek to Shave 'Tacked On' Claims From MDL Complaint
3 minute readLawsuit Against Major Food Brands Could Be Sign of Emerging Litigation Over Processed Foods
3 minute readPlaintiff Argues Jury's $22M Punitive Damages Finding Undermines J&J's Talc Trial Win
4 minute readProducts Liability: The Absence of Other Similar Claims—a Defense or a Misleading Effort to Sway a Jury?
Trending Stories
- 1Critical Mass With Law.com's Amanda Bronstad: 700+ Residents Near Ohio Derailment File New Suit, Is the FAA to Blame For Last Month's Air Disasters?
- 2Law Journal Column on Marital Residence Sales in Pending Divorces Puts 'Misplaced' Reliance on Two Cases
- 3A Message to the Community: Meeting the Moment in 2025
- 4Ex-Prosecutor Denies on Witness Stand That She Tried to Protect Ahmaud Arbery's Killers
- 5Latham's Lateral Hiring Picks Up Steam, With Firm Adding Simpson Practice Head, Private Equity GC
Who Got The Work
J. Brugh Lower of Gibbons has entered an appearance for industrial equipment supplier Devco Corporation in a pending trademark infringement lawsuit. The suit, accusing the defendant of selling knock-off Graco products, was filed Dec. 18 in New Jersey District Court by Rivkin Radler on behalf of Graco Inc. and Graco Minnesota. The case, assigned to U.S. District Judge Zahid N. Quraishi, is 3:24-cv-11294, Graco Inc. et al v. Devco Corporation.
Who Got The Work
Rebecca Maller-Stein and Kent A. Yalowitz of Arnold & Porter Kaye Scholer have entered their appearances for Hanaco Venture Capital and its executives, Lior Prosor and David Frankel, in a pending securities lawsuit. The action, filed on Dec. 24 in New York Southern District Court by Zell, Aron & Co. on behalf of Goldeneye Advisors, accuses the defendants of negligently and fraudulently managing the plaintiff's $1 million investment. The case, assigned to U.S. District Judge Vernon S. Broderick, is 1:24-cv-09918, Goldeneye Advisors, LLC v. Hanaco Venture Capital, Ltd. et al.
Who Got The Work
Attorneys from A&O Shearman has stepped in as defense counsel for Toronto-Dominion Bank and other defendants in a pending securities class action. The suit, filed Dec. 11 in New York Southern District Court by Bleichmar Fonti & Auld, accuses the defendants of concealing the bank's 'pervasive' deficiencies in regards to its compliance with the Bank Secrecy Act and the quality of its anti-money laundering controls. The case, assigned to U.S. District Judge Arun Subramanian, is 1:24-cv-09445, Gonzalez v. The Toronto-Dominion Bank et al.
Who Got The Work
Crown Castle International, a Pennsylvania company providing shared communications infrastructure, has turned to Luke D. Wolf of Gordon Rees Scully Mansukhani to fend off a pending breach-of-contract lawsuit. The court action, filed Nov. 25 in Michigan Eastern District Court by Hooper Hathaway PC on behalf of The Town Residences LLC, accuses Crown Castle of failing to transfer approximately $30,000 in utility payments from T-Mobile in breach of a roof-top lease and assignment agreement. The case, assigned to U.S. District Judge Susan K. Declercq, is 2:24-cv-13131, The Town Residences LLC v. T-Mobile US, Inc. et al.
Who Got The Work
Wilfred P. Coronato and Daniel M. Schwartz of McCarter & English have stepped in as defense counsel to Electrolux Home Products Inc. in a pending product liability lawsuit. The court action, filed Nov. 26 in New York Eastern District Court by Poulos Lopiccolo PC and Nagel Rice LLP on behalf of David Stern, alleges that the defendant's refrigerators’ drawers and shelving repeatedly break and fall apart within months after purchase. The case, assigned to U.S. District Judge Joan M. Azrack, is 2:24-cv-08204, Stern v. Electrolux Home Products, Inc.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250