Justia U.S. 3rd Circuit Court of Appeals Opinion Summaries

A 36 year-old schoolteacher sustained serious brain injuries when he was struck by a car while bicycling to work. His parents, appointed as his legal guardians, filed a products liability suit against the manufacturer of the bicycle helmet their son wore during the collision. The district court permitted the manufacturer to introduce expert testimony, based in part upon the United States Consumer Product Safety Commission's Safety Standard for Bicycle Helmets (16 C.F.R. 1203). Ultimately, experts for both sides agreed that the CPSC Standard forms the starting point for any bicycle helmet design, and that the helmet at issue satisfied the CPSC Standard in all respects. The court instructed the jury pursuant to sections 1 and 2 of the Restatement (Third) of Torts. The Court also instructed the jury that, in determining whether the helmet was defective, it could consider evidence of standards or customs in the bicycle helmet industry, including the CPSC Standard. The jury returned a verdict for the defense. The Third Circuit affirmed, holding that the jury instructions and admission of the CPSC standard represented Pennsylvania law.

Plaintiff was unloading a railway tank car filled with sulfuric acid when its chemical contents exploded, spraying across his face and chest and inflicting severe burns. He sought damages under the common law, but the district court held that his lawsuit was preempted by the Hazardous Materials Transportation Act, 49 U.S.C. 5101–5128. The Third Circuit affirmed. The Act expressly preempts any common law requirement about the design of a package, container, or packaging component qualified for use in transporting hazardous materials in commerce. The tank car at issue is a container qualified for such use, regardless of whether what plaintiff was doing constituted transport or his employment status at the precise moment of his injury.