Background
Howard Meyers was injured on July 29, 2019, when an automatic overhead Pharma-Roll Door manufactured by Rytec Corporation struck him in the head as he walked underneath it while it was closing at a Pfanstiehl Labs facility. Surveillance video confirmed Meyers was hit while the door was descending. A subsequent root cause analysis revealed no interior safety sensor existed on the door. Pfanstiehl Labs had purchased the door from Paul Reilly Company Illinois, Inc. in November 2007, adding explosion-proof components to the standard design.
Meyers filed suit in May 2021 asserting negligence, res ipsa loquitur, and product liability claims. His theories centered on three alleged failures by Rytec: failing to provide adequate installation instructions, failing to properly train maintenance technicians, and manufacturing the door in violation of applicable codes. By the time of summary judgment, Meyers had voluntarily dismissed claims against most defendants, leaving only Rytec as the remaining manufacturer defendant.
The circuit court granted Rytec’s motion for summary judgment on March 25, 2025, finding no genuine issue of material fact regarding breach of duty. Meyers appealed, focusing his arguments on the adequacy of Rytec’s written instructions and training of the distributor’s technicians.
The Court’s Holding
The appellate court affirmed the summary judgment, holding that Rytec had satisfied any duty of reasonable care through adequate warnings and instructions. The court found Rytec’s manuals—the Installation Manual, Owner’s Manual, and Drive & Control Manual—expressly stated that the door required two photo eye safety sensors, one mounted on the front and one field-installed on the back. The manuals specifically warned that the door would lower and potentially strike personnel or objects if the photo eyes did not operate properly. The court rejected Meyers’ argument that these instructions lacked sufficient cautionary language, finding the warnings unambiguous regarding the necessity of dual photo eye installation for safety.
Regarding Meyers’ criticism of a site-specific architectural drawing that depicted only the backside of the door, the court held Rytec bore no responsibility for that drawing since it was prepared by an independent architect hired by Pfanstiehl, not by Rytec. The court noted that manufacturers are entitled to presume that recipients will read the detailed instruction manuals provided, not rely solely on architectural drawings. The drawing itself actually depicted a photo sensor on the back of the door, undermining Meyers’ claim that installers lacked guidance.
As to Meyers’ argument that Rytec negligently trained the distributor’s maintenance technicians, the court found the claim either forfeited due to insufficient legal support or meritless. Even assuming Rytec voluntarily undertook a duty to train third-party technicians, any breach would constitute mere nonfeasance—a failure to train—rather than misfeasance requiring actionable negligence. Additionally, Meyers presented no evidence he relied on Rytec’s training in any way, defeating proximate causation under a voluntary undertaking theory.
Key Takeaways
- Manufacturers may satisfy the duty to warn through clear, unambiguous written instructions in manuals, even if warnings do not use specific cautionary language like “risk of serious injury.”
- A manufacturer is not responsible for the adequacy of site-specific design drawings prepared by third-party architects or engineers hired by the customer, provided the manufacturer’s own instructional materials are adequate.
- Manufacturers are entitled to the presumption that recipients will read and follow instruction manuals provided with a product, and need not account for the possibility that users will rely exclusively on architectural drawings instead.
- Claims of negligent training against manufacturers can succeed only through proof of an affirmative misfeasance (improper training), not mere nonfeasance (failure to train), and require evidence that the plaintiff relied on the training in question.
Why It Matters
This decision reinforces manufacturers’ ability to discharge their duty of care through adequate written warnings and instructions, even when customer modifications occur post-purchase. The ruling emphasizes that manufacturers need not second-guess how third parties—such as independent architects, installers, or service contractors—will implement their designs. The clear and unambiguous standard for warning sufficiency means manufacturers cannot be held liable for inadequate warnings based on the absence of alarmist language when the substantive safety information is clearly communicated.
The decision also clarifies the limits of negligent training claims in the products liability context, holding that such claims require either an employer-employee relationship or proof of affirmative misfeasance—not merely a failure to provide optional training. For manufacturers who offer training to dealers and customers, the decision suggests that offering training at all does not automatically create liability for the manner in which third parties implement that training, provided the manufacturer has not actively misdirected them. The ruling also reflects judicial deference to summary judgment where instruction manuals are clear and unambiguous, limiting fact disputes in products liability cases.