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Lightolier v. Hoon6/21/2005
Bell, C. J., Raker, Wilner, Cathell, Harrell, Battaglia, Greene, JJ.
Bell, C.J., Wilner and Battaglia, JJ. dissent.
This case arises from the occurrence of a fire that caused substantial damage to the home of David and Texie Hoon ("the Hoons"). At issue is whether the manufacturer of a recessed light fixture that gave rise to the fire when it was later improperly surrounded by thermal insulation can be strictly liable under a product liability theory when warnings existing on both the light fixture itself and the instruction manual accompanying it clearly warned of a risk of fire if the light fixture was placed in close proximity to thermal insulation.
On November 15, 1999, the Hoons and their insurer, Federal Insurance Company, respondents, filed a complaint in the Circuit Court for Kent County against numerous defendants including Lightolier, a Division of Genlyte Thomas Group, LLC ("Lightolier"), petitioner, with the specific claims against Lightolier being for negligence, breach of warranty and product liability - defective design. Lightolier, a designer and manufacturer of lighting products, including the light fixture alleged to have been involved in starting the fire that damaged the Hoons' home, thereafter filed a motion for summary judgment with the Circuit Court on March 15, 2002. On April 15, 2002, the Circuit Court granted Lightolier's motion for summary judgment.
The Hoons thereafter filed an appeal to the Court of Special Appeals. On September 15, 2004, the intermediate appellate court issued its opinion, Hoon v. Lightolier, 158 Md.App. 648, 857 A.2d 1184 (2004), which reversed the Circuit Court's granting of Lightolier's motion for summary judgment. On November 1, 2004, Lightolier filed a Petition for Writ of Certiorari to this Court. On December 17, 2004, we granted the petition. Lightolier v. Hoon, 384 Md. 448, 863 A.2d 997 (2004). Lightolier presents one question for our review:
"Where a manufacturer supplements its undisputedly sufficient warnings accompanying its product with an additional safety feature, does the manufacturer forfeit its right to assume that those warnings will be read and heeded, such that misuse of the product in direct contravention of those warnings is no longer deemed the proximate cause of damages under the law, even though the product is safe for use when the warnings are followed?"
We hold that, because adequate warnings were placed on the Lightolier light fixture at issue that warned of the risk of fire if thermal insulation was thereafter placed within three inches of the light fixture, and it is undisputed that the fire would not have occurred if these warnings had been heeded, the proximate cause of the fire was the negligent placement of thermal insulation within three inches of the already installed light fixture, thereby resulting in a misuse of the fixture. Therefore, the Circuit Court properly entered summary judgment in favor of Lightolier upon its motion.
I. Facts
A. The Hoons' Home Renovation and Ensuing Fire
While in the process of making extensive renovations to their Chestertown, Maryland home, David and Texie Hoon designated that non-IC rated recessed light fixtures be installed in certain areas of their home. These non-IC rated fixtures were manufactured by Lightolier, Model 1002P1, and purchased in "early 1998." The actual installation of these non-IC rated fixtures was performed by Westwind Construction Company ("Westwind"), a company partly owned by David Hoon that acted as both the general contractor responsible for the renovations to the Hoons' home and as the electrical contractor. Printed on each of the Lightolier non-IC rate
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