Products Liability Law Daily Wrap Up, DESIGN AND MANUFACTURING DEFECTS—INDUSTRIAL AND COMMERCIAL EQUIPMENT—W.D. Wash.: Case over worker injured by scissor lift will proceed to trial, (Jan 13, 2026)

By Brian Craig, J.D.

An expert report could allow a reasonable juror to find that there is a factual connection between the lift’s brake design and the workplace accident to support the design defect claim.

In a case involving a worker injured by a scissor lift, the federal district court in Washington has held that defect and failure to warn claims against scissor lift manufacturer Custom Equipment LLC and negligence claims against equipment rental company Sunbelt Rentals, Inc. can go to trial. In denying the scissor lift manufacturer’s motion for summary judgment, the court held that the worker’s expert report could allow a reasonable juror to find that there is a factual connection between the lift’s brake design and the workplace accident to support the design defect claim.

The worker also presented sufficient evidence that would allow a reasonable jury to find the lift’s emergency stop button was miswired at the time of the accident to support the negligence claim against the equipment rental company (Hartley v. Sunbelt Rentals, Inc., Case No. 24-cv-01078-JHC (W.D. Wash. Jan. 9, 2026)).

A worker was injured while operating a scissor lift between buildings. As the worker navigated down a ramp, he let go of the joystick that controlled the movement of the lift because the lift was starting to speed up. When he released the joystick, the worker expected the lift to stop moving. Instead, the lift kept speeding up, even after he hit the lift’s emergency stop button (e-stop). The lift then collided with a concrete wall and came to an abrupt stop causing injuries to the worker. The worker filed suit in Washington state court alleging Washington state law claims. The worker alleges design defect and failure to warn claims against the manufacturer of the scissor lift Custom Equipment LLC as well as negligence against the equipment rental company, Sunbelt Rentals, Inc. In addition, the worker alleges res ipsa loquitur against both the manufacturer and the equipment rental company. After the case was removed to the federal district court, the lift manufacturer and the equipment rental company moved for summary judgment.

Design defect. The court concluded that the worker presented sufficient evidence for a reasonable jury to support the design defect products liability claim against the scissor lift manufacturer. The worker submitted an engineer’s expert report to support the design defect theory that the lift’s parking brakes were a root cause of the accident. The expert report could allow a reasonable juror to find that there is a factual connection between the lift’s brake design and the workplace accident to support the design defect claim. The court concluded that “but for” causation remains a question for the jury. Thus, the court denied the manufacturer’s motion for summary judgment on the design defect claim.

Failure to warn. The court also denied the scissor lift manufacturer’s motion for summary judgment on the failure to warn claim. The manufacturer asserted that the failure to warn claim is based on speculation that the brake levers were in the intermediate position, but the court rejected this argument. The worker’s expert report establishes that the position of the brake levers is a material fact in dispute. Furthermore, the manufacturer raised the speculation theory for the first time in its reply brief and the manufacturer failed to address the elements of a failure to warn claim.

Negligence. Besides the claims against the lift manufacturer, the court ruled that the negligence claim against the equipment rental company can also proceed to trial. The worker presented evidence that would allow a reasonable jury to find the lift’s e-stop was miswired at the time of the accident. The evidence shows that the e-stop wiring was repaired multiple times before the accident. There is circumstantial evidence that the technician did not consult a wiring diagram to conduct this repair. Thus, the court denied the equipment rental company’s motion for summary judgment on the negligence claim.

Res ipsa loquitur. While the court permitted the other claims to proceed to trial, the court held that the worker failed to establish sufficient facts supporting res ipsa loquitor. Under res ipsa loquitor, the injuries are caused by an agency or instrumentality within the exclusive control of the defendant. In this case, the worker’s testimony shows that he was operating the lift at the time of the accident. The worker also testified that he conducted a daily lift inspection on the day of the incident. The worker identified no evidence that would allow a reasonable juror to find the defendants possessed a superior or exclusive position for obtaining knowledge about the facts of the accident. Thus, the evidence shows that the worker’s injuries were not caused by instrumentalities within the exclusive control of the manufacturer or equipment rental company.

Therefore, the court denied motions for summary judgment on the design defect, failure to warn, and negligence claims, but granted the motion to summary judgment on the res ipsa loquitor claim.

The case is No. 24-cv-01078-JNC.

Judge: Chun, J.

Attorneys: Paul Alexander Lindenmuth (Law Offices of Ben F. Barcus) for Matthew Hartley. Philip Randolph Meade (Merrick, Hofstedt & Lindsey, P.S.) for Sunbelt Rentals Inc. and Custom Equipment LLC.

Companies: Sunbelt Rentals Inc.; Custom Equipment LLC; Stratford-Cambridge Group (SGI)

Cases: CourtDecisions CausationNews DesignManufacturingNews IndustrialCommercialEquipNews WarningsNews