Products Liability Law Daily Wrap Up, DESIGN AND MANUFACTURING DEFECTS—INDUSTRIAL AND COMMERCIAL EQUIPMENT—8th Cir.: District court’s grant of summary judgment to boiler manufacturer in injured worker’s strict liability and negligence case affirmed, (Jun 16, 2026)

By Kerry McInerney, J.D.

A poultry plant worker who was allegedly injured by an exploding boiler during an inspection did not have sufficient evidence for a strict products liability or negligence claim.

The U.S. Court of Appeals in St. Louis (8th Cir.) affirmed a district court’s grant of summary judgment to a boiler manufacturer, determining that a poultry plant worker, who was injured while inspecting a boiler at work, failed to present sufficient evidence to support strict products liability and negligence claims (Rhodes v. Fulton Thermal Corp., No. 25-1849 (8th Cir. June 12, 2026)).

Arkansas has adopted a strict liability theory of recovery for products liability cases and the court looked for genuine issues of material fact to assess the motion for summary judgment.

Background. A poultry plant worker, who was injured when a boiler made by the manufacturer caught fire and exploded while he was performing a monthly check of the boiler, brought suit against the boiler manufacturer based on strict liability and negligence claims. The worker saw a “cloud of white stuff,” heard a “mechanical sound,” and then the boiler exploded in front of him. He suffered severe burns.

The manufacturer’s employees performed quarterly and yearly checks on the plant’s boilers, and had done a quarterly inspection three days before the explosion. The yearly inspection occurred three months before the explosion and included a physical examination of the internal components.

The district court granted summary judgment, finding no evidence that the manufacturer breached a duty, supplied a defective boiler, or proximately caused the worker’s injuries. The worker appealed the ruling.

Strict products liability. The injured worker’s strict products liability claim could only survive a motion for summary judgment if there was a genuine issue of material fact. The worker argued that the district court erred by granting summary judgment due to genuine disputes of material fact whether the manufacturer supplied a defective boiler and negligently inspected and serviced it.

In Arkansas, to prevail under a strict liability theory, a plaintiff must prove (1) the defendant was “engaged in the business of manufacturing, assembling, selling, or leasing, or otherwise distributing the product”; (2) the product was supplied by him in a defective condition which rendered it unreasonably dangerous; and (3) the defect was the proximate cause of the plaintiff’s damages. The court noted that circumstantial evidence can be enough to prove a manufacturing defect if the evidence is “substantial,” sufficient to “force or induce the mind to pass beyond suspicion and conjecture.”

The worker contended that, absent a defect, the boiler would not have exploded. He believed that his expert and the manufacturer’s service technician negated alternative causes of the accident and that, as supported by eyewitness testimony, a defect caused the explosion.

The appellate court determined that his argument failed. His expert had acknowledged that “dozens” of ignition sources existed outside the boiler, conceded he did not know how the coils malfunctioned, and could not identify a manufacturing or a design defect. His testimony did not sufficiently negate other possible causes of failure and create a reasonable inference of a defect. Also, the service technician’s confirmation of a single coil malfunction in a different plant, and the worker’s and his supervisor’s belief that the explosion originated in the boiler, did not negate other possible causes. The court ruled that the worker’s explanation for the explosion was insufficient to create a genuine dispute of material fact.

Negligence. The worker argued that the manufacturer’s inspections of the 21-year-old internal coils were inadequate because technicians entering the boiler would examine (at most) 25 percent of the boiler’s tubing. He also contended that the white cloud before the explosion was consistent with a coil perforation that leaked the thermal fluid within, which the service technician admitted had occurred once before. The worker further believed that his expert’s testimony showed that the manufacturer should have required radiographic inspections, covering not-examined inner tubes, outer tubes, the heat exchanger, and coke buildup.

Negligence can be established by direct or circumstantial evidence, but a plaintiff cannot rely on “inferences based on conjecture or speculation” to demonstrate proximate cause. The court noted this is usually a determination for the jury, but is left to the court when reasonable minds could not differ.

The appellate court responded, finding that even if the worker proved a duty and a breach, he failed to present evidence of proximate causation. The court explained that the worker ignored his expert’s admissions: (1) no evidence showed any perforation before the explosion; and (2) if the fire had been caused by a malfunctioning internal coil, it would have occurred “pretty soon before the fire,” and likely would have produced physical evidence of a leak. The court noted that it was undisputed that the manufacturer regularly inspected the boilers—including three days before the incident—and identified no issues. Proximate causation could not be established where the worker could not prove that there was any detectable perforation when the manufacturer inspected the boiler.

The district court’s judgment on the strict liability and negligence claims was affirmed.

The case is No. 25-1849.

Judge: Benton, D.

Attorneys: William David Carter (Mercy & Carter L.L.P.) for Triston James Rhodes. Ben C. Hall (Barber & Munson) for Fulton Thermal Corp.

Companies: Fulton Thermal Corp.

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