Expert Witness Blog
Davis v. Globe Machine Manufacturing Co.
A notable case involving a Machine Guarding Expert Witness is Davis v. Globe Machine Manufacturing Co., decided by the Washington Supreme Court in 1984. This case centered on workplace safety, specifically the adequacy of machine guarding on industrial equipment, and provides a clear example of how expert testimony can shape the outcome of litigation involving industrial accidents and alleged product defects. The full opinion is available at Davis v. Globe Machine, 102 Wn.2d 68 (1984).
Background and Facts
The plaintiff, Davis, was employed at a facility where she operated a machine manufactured by Globe Machine Manufacturing Company. The machine in question contained rollers used in the manufacturing process. During cleaning, Davis reached into the machine to remove debris while the rollers were still moving, resulting in a severe hand injury. Davis alleged that the machine was defectively designed because it lacked adequate guarding at the “nip point”—the hazardous area where the rollers met and could catch a worker’s hand.
Parties and Claims
Davis sued Globe Machine Manufacturing Co., claiming that the machine was not reasonably safe due to insufficient guarding and that the manufacturer failed to provide adequate warnings or instructions regarding safe cleaning procedures. Globe Machine denied liability, arguing that the machine was adequately guarded for its intended use and that Davis’s actions constituted an unreasonable misuse of the equipment.
Role and Methods of the Machine Guarding Expert Witness
Both parties presented expert testimony regarding the adequacy of the machine’s guarding:
- For the plaintiff, Leslie Ball, a Machine Guarding Expert Witness, testified that the primary hazard was at the nip point and that the machine’s design failed to adequately protect operators during cleaning. Ball described industry standards for machine guarding and opined that additional safeguards could have prevented the accident.
- The defense called several experts, including Clifford Pearson, who argued that while a guard could enhance safety during operation, it would not necessarily improve safety during cleaning. Other defense experts, such as Frank Roberts and Gordon Robinson, testified that the machine was adequately guarded for certain cleaning methods and that Davis had assumed an unreasonable risk by reaching into the machine while it was running.
The experts relied on a combination of industry standards, engineering principles, and their own experience in machine safety to support their opinions. They examined the machine’s design, the presence and effectiveness of existing guards, and the foreseeability of cleaning procedures that might expose workers to hazards.
Court’s Reliability and Daubert Analysis
The Washington Supreme Court considered the admissibility and weight of the expert testimony in light of the facts and the applicable legal standards. The court did not explicitly reference the federal Daubert standard, as Washington courts apply their own criteria for expert evidence, but it did assess whether the testimony was based on reliable principles and methods relevant to the case.
The court found that both sides’ experts were qualified and that their testimony was relevant to the central issue: whether the machine was reasonably safe as designed and whether additional guarding was required under industry standards. The court also evaluated whether the plaintiff’s conduct—reaching into the machine while it was running—constituted contributory negligence or misuse sufficient to absolve the manufacturer of liability.
Impact of the Expert Testimony on the Outcome
The expert testimony was pivotal in framing the jury’s understanding of what constituted reasonable safety in machine design and operation. The court ultimately held that the adequacy of the machine’s guarding and the foreseeability of the plaintiff’s actions were questions for the jury, supported by the competing expert opinions. The case illustrates how a Machine Guarding Expert Witness can clarify technical safety standards and influence the determination of liability in industrial accident litigation.