Products Liability Law Daily Wrap Up, DESIGN AND MANUFACTURING DEFECTS—HOUSEHOLD PRODUCTS—E.D. Cal.: Consumer’s claims against cooler maker move forward in finger injury case, (Aug 24, 2026)

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

A consumer sufficiently alleged that his cooler’s tow handle created an unexpected pinch hazard during foreseeable use and caused his finger injury.

In a case brought against a cooler manufacturer by a consumer whose finger was severely injured when the cooler’s tow handle allegedly pinched it against the cooler body, a federal district court in California denied the manufacturer’s motion to dismiss amended strict-liability and negligence claims. The court held that the consumer plausibly alleged a design defect under California’s consumer-expectations test by describing foreseeable use of the cooler and alleging that an ordinary consumer would not expect the tow handle to cause severe finger injuries during unloading. The manufacturer’s call for more information was better reserved for discovery, and the evidence of a subsequent recall involving substantially similar fingertip injuries supported causation (Lee v. Igloo Products Corp., No. 2:25-cv-01526-JAM-CSK (E.D. Cal. Aug. 19, 2026)).

Background. In June 2023, a man filled an Igloo cooler with about 40 pounds of ice and beverages for a family gathering and transported it in the bed of his truck. When he and his cousin attempted to unload the cooler, the man held the side with the tow handle while his cousin held the opposite side. As they lifted the cooler from the truck, the tow handle allegedly pinched the man’s left index finger against the cooler body, removing his fingernail and a chunk of his left finger. He claimed that the cooler’s design permitted his hand to become trapped between the tow handle and cooler during normal, foreseeable use. Following his injury, the manufacturer recalled approximately 1 million of its coolers, including the subject cooler, after receiving 12 reports of fingertip injuries, including amputations, fractures, and lacerations allegedly caused by the tow handle pinching users’ fingers against the cooler. The consumer brought suit and asserted four claims, which the court dismissed without prejudice for being inadequately pleaded. In his operative Fourth Amended Complaint, he asserted strict products liability for design defect and negligence/negligent products liability for design defect. Igloo again moved to dismiss, arguing that the amended complaint still failed to establish a design defect or causation.

Legal standard. California recognizes two tests for establishing a design defect: the consumer expectations test and the risk-benefit test. Lucas v. City of Visalia, 726 F. Supp. 2d 1149, 1154 (E.D. Cal. 2010). The consumer elected to proceed under the consumer expectations test, under which a product is defective if it fails to perform as safely as an ordinary consumer would expect when used in an intended or reasonably foreseeable manner. Smith v. Adobe Systems, Inc., No. C-11-1480 EMC, 2011 WL 4404152, at *2 (N.D. Cal. Sept. 21, 2011). A design-defect claim requires substantial evidence establishing both the defect and a causal relationship between the defect and injury. Stephen v. Ford Motor Co., 134 Cal. App. 4th 1363, 1373 (2005).

Design defect. Igloo argued that the consumer failed to provide details concerning how he removed the cooler, including the position of the truck bed and tow handle, where he placed his fingers, how he grabbed the handle, and whether he stood inside or outside the truck; which the manufacturer believed were necessary to establish that the consumer removed the cooler in a normal and foreseeable way at the time of the accident. The court found those additional details unnecessary at the pleading stage. The allegations that the consumer used the cooler to store and transport beverages, kept it in his truck, and attempted to remove it from the truck were sufficient to plausibly establish intended or reasonably foreseeable use. The consumer also adequately alleged that an ordinary consumer would not expect the tow handle to pinch his digits against the cooler body during the ordinary act of unloading it. The subsequent recall further supported this allegation because it involved numerous substantially similar fingertip injuries and indicated that the hazard was serious enough to warrant a recall. The manufacturer’s desire for further details regarding the manner of removal was better left for discovery. The court therefore found that the consumer plausibly alleged a design defect and declined to dismiss either claim.

Causation. Igloo argued that the consumer merely speculated that a design defect caused his injury, that he improperly relied on the recall notice to establish liability, and that the tow handle could have pinched his finger for reasons unrelated to a defect. The court found the allegations sufficient because the consumer alleged that the cooler was defective when he purchased and used it and that the defect caused his injury. The recall did not constitute the sole basis for causation but added weight to the allegation that the subject cooler was defective because it had been recalled following substantially similar injuries. Construing the allegations in the consumer’s favor, the court concluded that he had plausibly pleaded causation and denied Igloo’s motion to dismiss.

The case is No. 2:25-cv-01526-JAM-CSK.

Judge: Mendez, J.

Attorneys: Adam John Kress (Johnson Becker PLLC) for Gary Lee. Erica W. Rutner (Cozen O'Connor) for Igloo Products Corp.

Companies: Igloo Products Corp.

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