Products Liability Law Daily Wrap Up, DESIGN AND MANUFACTURING DEFECTS—INDUSTRIAL AND COMMERCIAL EQUIPMENT—S.D. Ga.: Cooker manufacturer cannot escape liability in peanut oil plant fire case, (Oct 23, 2025)

By Molly Platnick

An injured technician’s evidence was sufficient to plead strict liability, negligence, and failure to warn claims.

The federal district court for the Southern District of Georgia denied a manufacturer’s motion to dismiss a case brought by a former peanut oil plant employee who was severely burned by an allegedly defective discharge chute. The former employee alleged strict liability; negligence in design, manufacture, and maintenance; and failure to warn. The manufacturer argued it was not liable because it was only a “product seller” and did not owe a legal duty to the former employee. The court rejected this theory, finding the former employee’s evidence was sufficient to suggest the manufacturer could be liable under strict liability, negligence, or failure to warn (Moore v. Anderson International Corp., No. 5:25–CV–54 (S.D. Ga. Oct. 20, 2025)).

Background. The former employee was severely burned while working as a maintenance technician at a peanut oil plant in Douglas, Georgia. In 2023, he was tasked with fixing a “glow” in a hole in the discharge chute of a cooker used to extract peanut oil. He was able to put out the fire by discharging a fire extinguisher into the hole but was “engulfed in flames” when he opened the door to the discharge chute. Opening the door allowed air to enter the chute and caused fire to “shoot out” at the technician.

The discharge chute was part of an oilseed processing mill designed and implemented by third-party contractors. The peanut plant contracted with Anderson International, which commissioned a cooker with a discharge chute from Crown Iron Works. According to the former employee, the peanut plant’s agreement with Anderson required the manufacturer to “teach…personnel how to use the equipment and processes; and provide on-site technical support” between 2017 and 2018.

The peanut oil plant had a fire in a discharge chute in 2018, allegedly caused by organic peanut material getting lodged in the chute and igniting. The plaintiff claimed that despite their agreement, the manufacturers did not instruct the peanut oil plant on how to prevent or put out fires in the cookers. Representatives from both manufacturers were on site the day of the fire, but, according to the plaintiff, “rather than remedying the underlying issue,” the manufacturers “removed and disabled the safety system temperature monitoring.” Removing the temperature probe created the hole in the discharge chute that the former employee was later assigned to fix. After the fire, the peanut oil plant added access doors to the chutes. The manufacturers allegedly were aware the doors could be a safety hazard but did not warn the plant.

The former employee brought this suit in Georgia state court in May 2025. The manufacturers timely removed it to federal court. The former employee sought money damages from the manufacturers for (1) strict liability, (2) negligence in design, manufacture, and maintenance, and (3) failure to warn.

Strict products liability. A plaintiff has met the requirements of a strict liability claim under Georgia law if he shows that (1) the defendant was the manufacturer of the product; (2) the product was defective at the time it was sold; and (3) the product’s defect proximately caused his injury.

Here, the court was concerned with the first prong. A manufacturer is an entity that “assumes an active role in the production, design, or assembly of products.” To successfully state a claim under FRCP 8(a), a plaintiff need not need establish every element of a strict liability claim, and the “primary inquiry” is whether the complaint “provides notice of the role a defendant allegedly played in the creation of the product or system at issue.” Great detail is not required, but “general statements or vague labels” are not enough.

In this case, Anderson argued the former employee could not plausibly allege it was the cooker’s “actual” manufacturer and not a mere “product seller.” The employee, however, offered “factual support” of the company’s involvement in developing the processing mill and its components. The employee’s evidence “outlines the exact responsibilities” Anderson had in designing, implementing, and maintaining the cooker. The court found the employee plausibly stated a claim for strict products liability because he demonstrated that Anderson had sufficient notice of its role as the mill’s manufacturer.

Anderson contended that even if the former employee’s evidence showed it had some responsibility for the mill, it did not prove Anderson actually manufactured the cooker and discharge chute. However, to survive a motion to dismiss, a plaintiff “need not specifically plead all details surrounding the defect’s source.” The court found the question of whether Anderson was a manufacturer or product seller would be “better suited for resolution at a later stage in the litigation.”

Negligent design, manufacture, and maintenance. Georgia law permits plaintiffs injured by defective products to pursue a negligence-based claim for relief if they can show (1) the defendant had a legal duty to conform to a standard of conduct to protect against unreasonable risk, (2) the defendant breached this duty, (3) a causal connection between the defendant’s conduct and the plaintiff’s injury, and (4) the defendant’s breach of legal duty resulted in the loss or damage of the plaintiff’s legally protected interest.

Anderson alleged it did not owe the former employee a legal duty because it did not design or manufacture the allegedly defective cooker. The court reiterated the conclusions stated above and reaffirmed that the employee’s evidence was enough to suggest Anderson was the cooker’s manufacturer. Because all facts in a complaint are accepted as true when reviewing a motion to dismiss, the court rejected Anderson’s claim it had no actual legal duty to the employee.

Anderson claimed the employee’s complaint was silent regarding maintenance of the cooker. Georgia law stipulates a manufacturer or product seller assumes a legal duty to carry out further inspection/testing. Here, the court found there was “ample” evidence in the complaint to support that Anderson’s involvement gave rise to a legal duty. The complaint detailed Anderson’s role in commissioning and setting up the cooker, as well as removing the temperature probe. Thus, the company was obligated to remedy any issues that arose from the cooker.

The court found the former employee met the factual detail required to plead the remaining three elements of the negligent design, manufacture, and maintenance claim and denied the defendant’s motion to dismiss.

Failure to warn. To plead failure to warn, a plaintiff must show (1) the defendant had a duty to warn, (2) the defendant breached that duty, and (3) the breach proximately caused the plaintiff’s injury. Georgia case law holds “a manufacturer’s duty to warn is continuous, even after that product has left the control of the manufacturer to be sold or distributed.”

As with the previous two counts, Anderson contended it was not liable under a failure to warn theory because the former employee had failed to show it was the cooker’s manufacturer. Anderson argued, even if it was the manufacturer, there was nothing to suggest the warnings were deficient. Based on the reasoning above, the court was persuaded the former employee adequately alleged Anderson was the manufacturer, such that it could infer a continuing duty to warn. The court accepted the complaint’s evidence that Anderson’s warnings regarding the cooker were insufficient. The complaint stated Anderson was aware the peanut oil plant installed an access door on the discharge chute and “knew it was a safety problem,” but did not warn the plant of the danger.

The case is No. 5:25–CV–54.

Judge: Wood, L.

Attorneys: Alan J. Hamilton (Shiver Hamilton Campbell LLC) for Elias Levi Moore. Alphonsie Nelson (Quintairos, Prieto, Wood, & Boyer, P.A.) for Anderson International Corp. Melissa C. Greene (Copeland, Stair, Valz & Lovell, LLP) for Crown Iron Works Co. n/k/a Crown Iron Works Co., LLC.

Companies: Anderson International Corp.; Crown Iron Works Co. n/k/a Crown Iron Works Co., LLC

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