Allyson Bolden sued SharkNinja after sustaining injuries while using their Intellisense Kitchen System food processor. Bolden claimed a design defect led to the lid jamming, resulting in her injury when trying to remove it. Defendant SharkNinja challenged the admissibility of Plaintiff’s expert, Dr. Wade Lanning‘s, testimony, arguing his qualifications, reliability, and relevance were lacking.
Lanning, a materials scientist and safety engineer, conducted a thorough analysis of the food processor. His key findings included:
- Design Flaw: The lid could be attached in a misaligned manner, locking into place without engaging the safety mechanism, leading to jamming.
- Jamming Mechanism: Testing revealed the lid could jam due to this misalignment, consistent with Bolden’s experience. Scratches on Bolden’s bowl supported this conclusion.
- Lack of Warnings: The product manual lacked warnings about lid jamming.
- Ineffective Engineering Controls: The flexible bowl and shallow lug/notch design failed to prevent misalignment.
- Alternative Designs: Lanning suggested safer alternatives, like a square lid or twist-to-lock mechanism, already used in other products.
- Causation: He concluded the jammed lid, lack of warnings, and inadequate safeguards proximately caused Bolden’s injuries.
Materials Science Expert Witness
Wade Lanning is a forensic investigator who uses his expertise in materials science and engineering to determine how and why a failure or accident occurred. Lanning is also a safety engineer and analyzes how product design, manufacturing, instructions and warnings, and consumer behavior relate to an accident. Lanning investigates incidents of any scope, from minor property damage to major accidents involving loss of life. He also works as a consultant in material processing, failure analysis, and risk management, and conducts research in forensic investigation and accident prevention.
Discussion by the Court
Qualifications
SharkNinja argued Lanning, a materials scientist, was unqualified to opine on warnings.
The Court found Lanning’s experience in safety engineering and assessing warnings in consumer products, including food processing machinery, sufficient. Lack of specialization impacts weight, not admissibility.
Reliability
SharkNinja claimed Lanning’s force testing was inadequate and his opinions on alternative designs and causation were unreliable.
Force Testing of Jamming
Sharkninja claimed he did not test the force required to assemble the lid in a jamming fashion. The Court found that this was incorrect, and that Lanning had indeed performed force testing. Sharkninja then tried to change their argument, which the Court deemed waived. The Court also stated that even if the argument was not waived, that Lanning’s testing was sufficient.
Force Testing of Lid Removal
Sharkninja claimed that Lanning should have tested the force required to remove a jammed lid. The Court determined that his testing on the force of jamming, and the analysis of the damaged food processor was sufficient.
Alternative Designs
The Court deemed that testing of alternative designs was not always required, especially when certain of the alternative designs already exist in the industry. Moreover, the alternative designs are not complex.
Warning Opinions
Plaintiff did not allege that Bolden was injured because she did not know how to remove the lid under ordinary circumstances but instead that she was unable to remove the lid normally due to the jam which stopped the handle from raising fully and that no warnings were provided regarding risks associated with the lid jamming.
The Court ruled that Lanning’s warning opinions were not contrary to the record, as claimed by the Defendant.
Relevance
SharkNinja argued Lanning’s causation opinion was irrelevant as his test didn’t perfectly replicate Bolden’s experience.
The Court found Lanning’s test replicated the core of Bolden’s experience: the lid not releasing fully through the use of the release button, requiring removal of the lid through other means.
Held
The Court held that Wade Lanning is qualified, has employed a reliable methodology, and his opinions are relevant, and accordingly denied Defendant’s motion to exclude Lanning.
Key Takeaways:
The Court emphasized that:
- Daubert doesn’t require specific credentials; relevant expertise is sufficient.
2. Reliability can be established through scientific methods or professional experience.
3. Lack of specialization impacts weight, not admissibility.
4. Testing is one measure of reliability, but not always required.
5. Imperfect testing is a matter for cross examination.
Case Details:
| Case Caption: | Haigler V. Sharkninja Operating LLC |
| Docket Number: | 1:23cv326 |
| Court: | United States District Court, Illinois Northern |
| Order Date: | March 3, 2025 |
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