Products Liability Law Daily Wrap Up, DESIGN AND MANUFACTURING DEFECTS—HOUSEHOLD PRODUCTS—D. Mass.: Blender maker wins summary judgment in consumer’s injury case, (Nov 4, 2025)

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

The manufacturer could not be held liable for a defective design since the purported hazard was “open and obvious” to the user, and the remaining claims were conceded by the consumer.

In an action brought against a blender manufacturer by a man who suffered an injury when the blender’s blade assembly fell out while pouring, a federal district court in Massachusetts granted the manufacturer’s motion for summary judgment. The court found that the product’s lid, owner’s guide, and packaging expressly warned that the blade was unsecured, detachable, and must be removed while pouring with the pitcher lid open to avoid the risk of laceration. This knowledge was supplemented by the man’s mother's experience of the product’s blades falling out and the consumer was thus “aware of the risk of injury,” barring his claims (Rivera v. SharkNinja Operating LLC, No. 1:24-cv-11119-BEM (D. Mass. Oct. 31, 2025)).

Background. In May 2022, a man purchased a SharkNinja CO351B blender. He had previously used an older version of the same blender model for around 14 months without injury, although his mother informed him of an incident where she turned the product upside down and its blades came out and chipped the floor. The new product’s packaging contained multiple conspicuous warnings that the pitcher contained a blade assembly with “loose, SHARP blades.” The owner’s guide explained that the blade assembly was removable, not locked in place, not permanently attached to the pitcher, and fit loosely in the drive gear. Both the guide and product lid warned that the blade assembly must be removed if pouring with the lid removed and that “[f]ailure to do so will result in a risk of laceration.” On the day of the incident, the man hurriedly made a smoothie and took the pitcher’s lid off since the smoothie was too thick to be poured out of the spout. The blade assembly came out while pouring, injuring him. He filed suit against the blender’s manufacturer, SharkNinja Operating, LLC, asserting claims for a manufacturing defect, design defect, negligence, and breaches of implied warranties. SharkNinja moved for summary judgment and to exclude the consumer’s expert evidence.

Applicable law. “Under Massachusetts choice of law rules, ‘tort claims are governed by the law of the state where the alleged injury occurred, unless another state has a more significant relationship to the cause of action.’” Bergin v. Dartmouth Pharm. Inc., 326 F. Supp. 2d 179, 183 (D. Mass. 2004). Here, the man’s injury occurred in Virginia. Since the parties agreed that Virginia law governed, the court forewent its analysis and accepted this agreement. Borden v. Paul Revere Life Ins. Co., 935 F.2d 370, 375 (1st Cir. 1991).

Analysis. The plaintiff conceded his failure-to-warn count and did not oppose summary judgment as to the claims for a manufacturing defect and breach of implied warranty of fitness for a particular purpose. As such, only the design defect claims remained under a theory of negligence and implied warranty. The manufacturer believed that these claims were due for dismissal since (1) the man did not prove that the blender’s design performed below the minimum safety assumptions of ordinary consumers; (2) neither he nor his expert showed the existence of a safer alternative design; and (3) the man had no admissible expert testimony which is necessary to establish causation. SharkNinja also asserted two affirmative defenses: that the purported defect was open and obvious and the man’s contributory negligence barred the negligence claims.

In Austin v. Clark Equip. Co., 821 F. Supp. 1130, 1133 (W.D. Va. 1993), the Fourth Circuit interpreted Virginia law to hold that “a manufacturer is not liable for defective design... where the hazard is open and obvious” i.e., “if the person using the product is or should be aware of the risk.” Here, it was undisputed that the product’s packaging contained several conspicuous warnings about the unattached, loose, and sharp blades. The risk of laceration was also clearly identified in case a liquid was poured with the lid removed and the consumer’s mother had also expressly warned him of the risk of damage or injury from blades falling out. Accordingly, he was “aware of the risk.” As confirmed in Austin, “summary judgment is appropriate where a ‘reasonable jury could reach only one conclusion’” and the evidence here was such that reasonable minds could not differ that the nature of the hazard was open and obvious. Summary judgment was thus warranted as to the remaining claims since an open and obvious defect “bars recovery under [both] contract or tort theor[ies]” Freeman v. Case Corp., 118 F.3d 1011, 1014 (4th Cir. 1997). The motion to exclude was denied as moot.

The case is No. 1:24-cv-11119-BEM.

Judge: Murphy, B.

Attorneys: Adam John Kress (Johnson Becker PLLC) and Robert F. Foster (Meehan, Boyle, Black & Bogdanow, PC) for Jairo Renato Castro Rivera. Brandon L. Arber (Shook, Hardy & Bacon, LLP) for SharkNinja Operating LLC.

Companies: SharkNinja Operating LLC

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