Products Liability Law Daily Wrap Up, EXPERT EVIDENCE—HOUSEHOLD PRODUCTS—E.D. Pa.: Federal court grants summary judgment in lawnmower fire case, excludes plaintiffs' expert under Daubert, (Jan 29, 2026)

By Wendy Biddle, J.D.

Plaintiffs' fire causation expert was excluded for failing to conduct comparison testing that would validate his theory that a deformed muffler caused a garage fire.

The U.S. District Court for the Eastern District of Pennsylvania granted summary judgment to defendants Stanley Black & Decker, Inc. and MTD Products, Inc. in a product liability case arising from a 2022 lawnmower fire, finding that plaintiffs failed to establish any genuine issue of material fact regarding an alleged defect after the court excluded their expert witness's testimony. The court ruled that plaintiffs could not proceed with their strict liability, negligence, and breach of warranty claims because their sole expert witness failed to provide reliable testimony that the lawnmower contained a defect when it left the manufacturer's control (George v. Stanley Black & Decker, Inc., No. 2:24-cv-02035-CMS (E.D. Pa. Jan. 26, 2026)).

Background. The incident occurred on May 10, 2022, when Jaron George used his Cub Cadet LTX riding lawnmower, Model No. 13AX91AT010, to mow his lawn during his lunch break. After finishing, he drove the lawnmower directly into his garage without allowing it to cool. The lawnmower caught fire while sitting in the garage, causing substantial damage totaling $585,609.37 to the home's garage, two bedrooms, attic, and roof, along with smoke and water damage.

MTD Products manufactured the lawnmower before Nov. 17, 2008, and it was sent to a retailer for the 2009 mowing season. George purchased the lawnmower more than 10 years before the incident, making the machine approximately 13 years old at the time of the fire. He did not receive or review the operator's manual, which contained warnings about fire hazards from mowing unusually tall or dry grass, the importance of keeping the mower free of debris buildup, and the need to allow the machine to cool for at least five minutes before storage.

The record revealed that George had not performed maintenance according to the manual's schedule, never cleaned the lawnmower including obstructions to the cooling area, and never inspected it. Before the 2022 mowing season, he only checked oil and gas levels. During the off-season, he stored the lawnmower under a gazebo covered with a tarp in an area that was not watertight. The lawnmower had exceeded its seven-year average useful life, after which the manual required annual inspections by an authorized service dealer to ensure mechanical and safety systems functioned properly.

Expert testimony. George’s case centered on Michael Zazula’s opinion that the lawnmower's muffler canister had become distended and bowed over its 13 years of use, creating a quarter-inch gap between the muffler and the deflector. Zazula theorized this gap allowed hot exhaust gases to escape into the engine area, causing abnormally high temperatures that ignited debris and combustible material.

The court found multiple fatal flaws in Zazula's methodology under the Daubert standard and Federal Rule of Evidence 702. Most significantly, Zazula conducted temperature testing only on a used lawnmower that already had a deformed muffler and gap. He never performed comparison testing on a lawnmower without the deformation to determine whether the gap actually increased engine temperatures.

The court emphasized that Zazula "could have fully tested his hypothesis, but he chose not to." This omission proved critical because defendants' experts conducted exactly this comparison testing and found that "a small gap between the muffler and the muffler deflector does not allow for the escape of the exhaust gases resulting in increased temperatures during operation."

The court found that Zazula's methodology violated the National Fire Protection Association's NFPA 921 guidelines, which he claimed to follow. NFPA 921 requires developing a hypothesis through inductive reasoning and then testing it through deductive reasoning to disprove or refute the hypothesis. The court determined Zazula's one-sided opinion without proper testing was unreliable and constituted "subjective belief or unsupported speculation" rather than testimony based on "the methods and procedures of science."

Additionally, the court found Zazula's testimony failed the "fit" requirement because it was not based on valid reasoning and reliable methodology. The court noted that his conclusion about the gap causing increased temperatures was "too speculative and subjective" when he never conducted comparison testing while two defense experts who did such testing found no temperature differences.

The court separately excluded Zazula's testimony regarding the alleged defective condition of the lawnmower. When questioned about what manufacturing defect existed, Zazula could only point to the distended muffler and gap itself, stating that if he brought it to MTD, they would say "that's not right." He provided no specific evidence of what occurred during manufacturing to constitute a defect and offered no detailed explanation of any design defect.

The court found Zazula unqualified to testify about defects because he admitted he was not a design engineer regarding mufflers and exhaust systems, nor was he a warnings expert. The court cited Third Circuit precedent that an expert may be deemed generally qualified but still lack qualifications to testify outside their area of expertise. During his deposition, Zazula stated he was offering opinions on "fire causation" and "mechanical issues with the tractor" but not regarding defects.

Summary judgment. With Zazula's testimony excluded, the court found plaintiffs produced no evidence of any defect in the lawnmower, which is essential to establish strict liability, negligence, or breach of warranty claims under Pennsylvania law. The court granted summary judgment to Stanley Black & Decker because it had no involvement in manufacturing or distributing the lawnmower and did not acquire MTD until December 2021, years after the lawnmower's production.

For the claims against MTD, the court found plaintiffs failed to establish a genuine issue of material fact on any theory. Under Pennsylvania strict liability law, a plaintiff must prove the product was defective, the defect existed when it left the defendant's hands, and the defect caused the harm. Without expert testimony, plaintiffs could not meet this burden.

The court rejected plaintiffs' attempt to proceed under the consumer expectation test for design defects, finding that the alleged defect in the muffler and exhaust system of the lawnmower was beyond the scope of the average consumer's understanding. The court noted that an average consumer does not understand the inner workings of a lawnmower's exhaust system or how a small gap might affect engine temperature.

Regarding the risk-utility test, plaintiffs provided only general allegations that they would present expert testimony establishing a feasible, safer alternative design existed. The court found these vague statements insufficient to create a genuine issue of material fact, as plaintiffs failed to address the specific factors courts must consider under the risk-utility analysis.

The court also rejected plaintiffs' malfunction theory. Under this theory, plaintiffs must produce evidence of a malfunction, eliminate abnormal use, and eliminate reasonable secondary causes. The court found plaintiffs could not eliminate secondary causes given George's failure to properly maintain the lawnmower according to the manual's schedule, his failure to clean or inspect it, and the fact that the 13-year-old lawnmower was well past its seven-year average useful life without required annual inspections.

The court dismissed all claims with prejudice, concluding that reasonable minds could not differ about whether plaintiffs produced sufficient evidence to demonstrate the lawnmower was in a defective condition.

The case is No. 2:24-cv-02035-CMS.

Judge: Straw, C.

Attorneys: Steven Joseph Payne (Steven Joseph Payne, Attorney at Law) for Jaron George and Rachel E. George. Frederick W. Bode, III (Dickie, McCamey & Chilcote, P.C.) for Stanley Black & Decker, Inc. and MTD Products, Inc.

Companies: Stanley Black & Decker, Inc.; MTD Products, Inc.

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