Plaintiff was driving his forklift along an east-west corridor at the Quebecor plant when he collided with a forklift operated by a co-worker. Brown alleged that Raymond had sold the forklift in a defective and unreasonably dangerous condition, that Raymond had provided inadequate warnings, and that the brakes were not working properly at the time of the accident. Interpreting the TPLA and the caselaw construing it, the district court concluded that only the prudent-manufacturer test–not the consumer-expectation test–applied in assessing the dangerousness of a forklift, which is a complex industrial machine. Because expert testimony was necessary to prove a prima facie case under that test and because the testimony of Brown’s experts had been excluded, the district court granted partial summary judgment in favor of Raymond on the defective-design and inadequate-warning claims. The Sixth Circuit rejected the plaintiff’s argument that even complex products have simple aspects to them. The Tennessee Supreme Court’s recent decision in Brown v. Crown Equip. “helpfully clarifies that a forklift is a complex machine whose safety is best evaluated using the prudent-manufacturer test – a test under which expert testimony is required in order to reach the jury.” Brown v. Raymond Corp., 432 F.3d 640 (6th Cir. 2005).
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