Products Liability Law Daily Wrap Up, DESIGN AND MANUFACTURING DEFECTS—ELECTRONIC PRODUCTS—D. Mass: Apple wins dismissal of consumer’s claims in watch’s fall detection case, (Oct 5, 2026)

By Pankhuri Bhatnagar, B.A. LL.B.

The design and manufacturing defect counts failed because the subject watch was not designed to, or claimed to, detect all falls or trigger emergency assistance in every case.

In an action brought against a watch manufacturer by an aged woman who suffered a serious brain injury after falling from her staircase and not receiving assistance for thirteen hours, a federal district court in Massachusetts granted the manufacturer’s motion to dismiss. The watch’s failure to detect her fall or contact emergency services did not establish a warning defect because the product’s User Guide expressly clarified that the watch “cannot detect all falls” and can only “attempt to call emergency services” if a fall is detected. The consumer’s Chapter 93A claim failed because the underlying product claims failed and because the manufacturer’s advertisements did not amount to a specific technical promise regarding the product’s fall detection features (Lucash v. Apple Inc., No. 1:25-cv-13597-JEK (D. Mass. Sept. 30, 2026)).

Background. A 75-year-old woman purchased an Apple Watch in 2022 primarily because of its Fall Detection feature. That feature used an accelerometer to detect sudden acceleration changes, a gyroscope to determine the type of movement, and an SOS system for automatically calling the user’s emergency contacts. She configured the watch according to the User Guide and designated her son and daughter as emergency contacts. On Oct. 12, 2022, she fell down a flight of stairs, resulting in a serious brain bleed, and remained on the floor for 13 hours because the watch did not detect the fall or contact emergency services or her emergency contacts. She later sued Apple, alleging negligence, breach of implied warranty, negligent failure to warn, breach of implied warranty based on inadequate warnings, and Chapter 93A violations.

Failure to warn. The woman claimed that Apple was negligent and breached an implied warranty by not adequately warning her that its watch would not detect her fall or contact emergency services on her behalf. Both claims are governed by the same standard, the reasonableness of the defendant’s actions, and a product may be defective “‘if foreseeable users are not adequately warned of the dangers associated with its use.’” Evans v. Lorillard Tobacco Co., 465 Mass. 411, 439 (2013). Although the court assumed without deciding that Apple had a duty to warn that the watch could not detect all hard falls, it found the product’s warning legally adequate. The User Guide expressly stated: “Apple Watch cannot detect all falls” and “if” the watch detected a fall, it would “attempt to call emergency services.” Any reasonable user reading this language would understand that the watch may not detect all falls, hard or otherwise, or successfully contact emergency services after a fall.

The consumer complained that the User Guide was “not physically provided to” her but admitted that she researched the watch’s safety features. The instructions she relied upon for setting the fall detection feature in her watch were found in an online version of the User Guide only, and ended with the warning that the watch “cannot detect all falls,” thus supporting an inference that the warning was read and would be heeded. Knowlton v. Deseret Med., Inc., 930 F.2d 116, 123 (1st Cir. 1991). The consumer argued that the warning was buried, failed to attract attention, and was undermined by surrounding language suggesting that physically active users were more likely to trigger fall detection. The court rejected those arguments because the warning appeared in the feature’s setup section, was identified as an italicized “Note,” and was not contradicted by the surrounding text. Niedner v. Ortho-McNeil Pharm., Inc., 90 Mass. App. Ct. 306, 312 (2016). The court also rejected reliance on Apple’s commercials because the amended complaint did not allege that those advertisements specifically represented that Fall Detection would summon emergency services after every fall. The warning claims were therefore dismissed as a matter of law.

Product defect. Massachusetts law requires a design-defect claimant to identify a reasonable alternative design that could reduce or avoid the foreseeable risk without undue cost or interference with the product’s performance. Evans, 465 Mass. at 424. The woman alleged that the watch at issue was defectively designed as it did not detect her hard fall or message her contacts but the User Guide’s conditional language made it clear that the watch might sometimes “attempt to call emergency services” not that it would always function in that way. As for the contention that Apple should have improved the accelerometer, gyroscope, and SOS system, and added alerts when those features were not functioning, or allowed users to test the features; the court held that they were conclusory. They did not identify an alternative design used in the industry, explain how it could practically have been adopted, or allege that it could reduce the relevant risks at reasonable cost. The design claims therefore failed. A manufacturing defect requires a particular product to deviate from its intended design in a way that makes it unreasonably dangerous. As noted above, the watch was not designed to detect all falls and the SOS feature operated only if a hard fall was detected. Because the complaint did not identify any deviation from the watch’s design, the manufacturing-defect claims were also dismissed.

Chapter 93A. The woman also alleged an independent deceptive-advertising theory based on a January 2022 commercial depicting people receiving emergency or life-saving care after falling while wearing an Apple Watch. The court found that the commercial did not make representations about the watch’s Fall Detection mechanism, and the woman expressly disclaimed reliance on it to establish a specific technical promise. Because the commercial did not plausibly represent that the watch would detect every fall or summon emergency services, the Chapter 93A claim was dismissed. The court granted Apple’s motion to dismiss.

The case is No. 1:25-cv-13597-JEK.

Judge: Kobick, J.

Attorneys: Alexis R. Alban Cahill (Feinberg & Alban, P.C.) for Terry Lucash. Andrew S. Dulberg (Wilmer Cutler Pickering Hale and Dorr LLP) for Apple Inc.

Companies: Apple Inc.

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