Hood v. Ryobi America Corp.

Facts

Hood bought a fully assembled Ryobi TS-254 miter saw in Westminster, Maryland on February 25, 1995, to do home repairs. The saw had a ten-inch blade. A fixed metal guard covered the upper half of the blade. A clear plastic lower guard covered the rest and retracted as the saw met the wood. The owner's manual and the saw itself carried at least seven warnings not to run the saw without the guards in place. Two said serious injury could result. The next day, Hood tried to cut a piece of wood about four inches high, and the guards kept the blade from passing through. He took the blade off, unscrewed the four screws holding the guard assembly, and put the blade back on the bare spindle. He kept working without the guards for about twenty minutes. Then the blade flew off the saw toward him. It partially amputated his left thumb and lacerated his right leg. Hood admitted he had read the manual and most of the labels. He said he thought the guards only kept clothing or fingers away from the blade. He said he did not know that removing them could let the blade detach. He also claimed Ryobi knew of that risk. Another customer had sued Ryobi after a similar accident in the mid-1980s.

Issues

1. Under Maryland law, were Ryobi's warnings not to run the saw without its blade guards adequate as a matter of law, even though they did not say that removing the guards could let the blade detach?
2. Under Maryland law, does a consumer's alteration of a product, made in violation of clear warnings and leading directly to his injury, defeat a design defect claim?

Holding

Ryobi's repeated, clear warnings against using the saw without its guards were adequate as a matter of law. Because Hood's own alteration, made against those warnings, caused his injury, the saw was not defective in design. Ryobi was not liable under any theory raised.