Products Liability Law Daily Wrap Up, WARNINGS ISSUES—HOUSEHOLD PRODUCTS—Pa. Super.: Summary judgment for lawnmower suppliers upheld in consumer’s foot injury case, (Aug 27, 2026)

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

The consumer acted against the lawnmower’s existing warnings by mowing grass in an up-and-down manner rather than across, resulting in the dismissal of his warning defect claim.

In an action brought against a lawnmower’s manufacturer and seller by a consumer who sustained a severe foot injury from slipping and going under the walk-behind lawnmower, the Pennsylvania Superior Court affirmed judgment in favor of the suppliers. The consumer’s strict-liability failure-to-warn claim was properly dismissed because the existing warnings adequately identified the relevant danger and the evidence rebutted the presumption that he would have heeded an additional warning. There was no abuse of discretion in the trial court’s evidentiary rulings, including its admission of the manufacturer’s expert, exclusion of evidence concerning dissimilar prior incidents, and bifurcation of liability and damages (McDonnell v. MTD Products, Inc., No. 562 MDA 2025 (Pa. Super. Aug. 24, 2026)).

Background. In 2015, a consumer purchased an MTD-manufactured Troy-Bilt walk-behind lawnmower from Lowe’s as a discounted floor model without its original packaging or operator’s manual. The mower carried warnings instructing users to mow across slopes rather than up and down them and not to mow slopes exceeding 15 degrees. In October 2018, while mowing his backyard, which contained a sloped area, the consumer turned and proceeded down the slope before slipping on wet grass. His foot went beneath the mower and was severely injured by the blade, resulting in an 88-day hospitalization, 25 surgeries, and approximately $650,000 in medical expenses. He and his spouse sued MTD Products, Inc. and Lowe’s Home Centers LLC (together, suppliers), asserting claims for negligence, strict products liability, breach of warranty, and loss of consortium.

Prior proceedings. The consumer’s strict-liability claims alleged that the mower was defective because the distance between the rear of the deck and blade was inadequate, the mower lacked a guard preventing a user’s foot from reaching the blade, and its warnings were insufficient. His proposed additional warning would have instructed an operator who slipped to immediately release the operator-presence control and push the mower away. The claimants ultimately pursued the design-defect theory at trial after the failure-to-warn claim was dismissed on summary judgment. At trial, the claimants’ expert opined that the mower’s design was defective because of insufficient blade clearance and inadequate guarding and proposed an alternative design incorporating an extended rear deck. The suppliers’ expert testified that operating the mower straight down a slope of approximately 25 degrees constituted misuse and that the accident could have occurred even with the proposed alternative designs. A jury found that the mower did not have an unreasonably dangerous design defect and the trial court entered judgment for the companies, prompting this appeal.

Failure to warn. The claimants first argued that the trial court improperly granted summary judgment on their failure-to-warn claim because factual disputes remained concerning where the consumer fell, the slope’s degree, and how his foot reached the blade. They maintained that the mower should have warned users about the specific risk of blade contact during a slip and fall and instructed them to release the handle and push the mower away. A § 402A failure-to-warn claim requires proof that an inadequate warning caused the injury, and Pennsylvania law ordinarily gives claimants a rebuttable presumption that an adequate warning would have been heeded. L.T. v. Kubota Manufacturing of America Corp., 332 A.3d 47, 58-59 (Pa. Super. 2025). But once the defendant produces evidence sufficient to rebut that presumption, the burden shifts back to the claimant to show that he would have changed his conduct. Goldstein v. Philip Morris, Inc., 854 A.2d 585, 588 (Pa. Super. 2004). A manufacturer likewise has no duty to warn against dangers arising from a consumer’s failure to heed an adequate existing warning. Gigus v. Giles & Ransome, Inc., 868 A.2d 459, 463 (Pa. Super. 2005).

The mower already warned users to mow across slopes, never up and down, and not to mow slopes exceeding 15 degrees. It was immaterial whether the slope of the area where the consumer slipped exceeded 15 degrees since the warning instructed him to not mow up and down a slope at all. Mowing across the slope would have caused him to slide away from the mower due to gravity rather than under it. Accordingly, the trial court properly concluded that his injuries were caused by disregarding the product’s instructions. The man’s deposition statements established that he generally did not consult lawn-equipment manuals and only glanced at the mower’s on-product warnings rather than reading them carefully. Accordingly, the presumption about him heeding a warning was rebutted and the claimants offered no testimony, affidavit, or other evidence establishing that he would have read and followed an additional instruction to release the mower and push it away after slipping. Thus, they failed to establish causation, and summary judgment on the failure-to-warn claim was affirmed.

Evidentiary rulings. The claimants challenged several trial rulings, arguing that the court improperly allowed the suppliers to present evidence concerning warnings and alleged misuse, permitted their accident-reconstruction expert to testify, excluded evidence of other consumer injuries, and prevented the claimants from presenting the full extent of the consumer’s medical treatment during the liability phase. The appellate court reviewed these matters for abuse of discretion, Martin v. Chevrolet, 357 A.3d 1232, 1246 (Pa. Super. 2026), and found no abuse. The trial court had provided a reasonable basis for bifurcating liability and damages while still permitting the claimants to present testimony and photographs concerning the injuries relevant to the design-defect inquiry. It also adequately explained why the challenged warning evidence did not improperly introduce negligence concepts prohibited by Sullivan v. Werner Co., 306 A.3d 846 (Pa. 2023). The suppliers’ expert possessed sufficient specialized knowledge concerning lawnmower accidents to testify as an accident-reconstruction expert, and excluding evidence of other slip-and-fall lawsuits was proper because the claimants failed to establish substantial similarity between those incidents and the accident at issue. Accordingly, this court adopted the lower court’s reasoning and affirmed judgment in favor of MTD and Lowe’s.

The case is No. 562 MDA 2025.

Judge: Bowes, M.

Attorneys: Richard M. Jurewicz (Galfand Berger LLP) for Jerome and Cheyenne McDonnell. Michael Alan Muha (Dickie, McCamey & Chilcote, PC) for MTD Products, Inc. and Lowe’s Home Centers LLC.

Companies: MTD Products, Inc.; Lowe’s Home Centers LLC

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