Camacho v. JLG Industries Inc. (2023)
Plaintiff fell off a scissor lift. He sued the manufacturer alleging that the lift was designed defectively because a safety chain meant to secure the lift’s entrance invited human error. At trial, he presented evidence that defendant produced a nearly identical scissor lift that included a self-closing gate in place of the safety chain.
The trial court concluded that Camacho failed to present substantial evidence of causation and granted defendant’s motion for directed verdict. Plaintiff appealed.
In a 2-1 opinion, the Court of Appeal reversed. The court held that plaintiff made a prima facie showing of causation because, based on photographs in the record, “the jury could have reasonably inferred that had a self-closing gate been in place, [plaintiff’s] fall would have been prevented.” The court also held that a jury could have concluded defendant failed to adequately warn about the dangers of its scissor lift because the warning was far from the lift’s entrance and did not specify that the chain needed to be latched. The court concluded that, had the warning been more explicit (and closer to the entrance of the lift), plaintiff might not have fallen.
