Andrew Hall and Aaron Lindebak represented Lippert Components, Inc. and LCI Industries in a products liability case. Lippert Components, Inc. and LCI Industries manufacture electric steps for use on Recreational Vehicles. Plaintiffs allege that a rivet in a step manufactured by Lippert Components and LCI Industries failed, resulting in the death of David Burke. Plaintiffs alleged that Lippert was negligent in designing, manufacturing, and failing to warn; and was strictly liable for their defective design, pre-sale failure to warn, and post-sale failure to warn. Plaintiffs similarly alleged LCI Industries was negligent in designing, manufacturing, and failing to warn; and was strictly liable for their defective design, pre-sale failure to warn, and post-sale failure to warn.
Defendants filed for summary judgment, contending that they did not manufacture or design the step but instead purchased the company that did manufacture the step. Defendants also argued they were not negligent in designing, manufacturing, or failing to warn.
The United States District Court for the Northern District of Iowa found that Plaintiffs were precluded from recovery against Defendants for defective design and pre-sale duty to warn because companies cannot be held liable for pre-acquisition-related claims. The Court also found that Plaintiffs failed to meet their burden of proof to support their post-sale duty to warn claim. Finally, the Court found that Plaintiffs’ strict liability claims must be dismissed because Iowa law does not recognize strict liability claims for design defects or failure to warn claims.