Bhagvandoss v. Beiersdorf, Inc.

BILLINGS, Judge,

concurring in part and dissenting in part.

I dissent from the principal opinion to the extent that it declares as a matter of law that the evidence was insufficient to submit the punitive damage instruction. Defendant knew of several cases of rhizopus infection following surgery in which Elastoplast had been used and that rhizopus was present in its own stocks of Elastoplast. Despite this knowledge of the hazards to patient safety that could result from the common use of Elastoplast to fix sterile dressings over open surgical wounds, defendant failed to issue a warning which clearly cautioned against this use. Inadequate warnings can support an instruction on punitive damages. Where a warning does not clearly state the known hazards of product use, the jury should be allowed to decide whether the warning is so inadequate as to constitute complete indifference to or conscious disregard for the safety of others. See Mulligan v. Lederle Laboratories, 786 F.2d 859, 864-66 (8th Cir.1986); Hoffman v. Sterling Drug, Inc., 485 F.2d 132, 146 (3d Cir.1973); Wooderson v. Ortho Pharmaceutical Corp., 235 Kan. 387, 415-20, 681 P.2d 1038, 1060-64, cert. denied, 469 U.S. 965, 105 S.Ct. 365, 83 L.Ed.2d 301 (1984). Although none of these decisions is binding on this Court, their holdings on this issue comport with sound policy. A defendant should not escape liability for punitive damages simply because it issues a warning which it should realize is inadequate to clearly warn against the known dangers of its product.

The principal opinion states that inadequate communciation cannot be equated to conscious disregard and cites to DeLuryea v. Winthrop Laboratories, 697 F.2d 222, 230-31 (8th Cir.1983); Johnson v. Husky Industries, Inc., 536 F.2d 645, 651 (6th Cir.1976), and Kritser v. Beech Aircraft Corp., 479 F.2d 1089, 1097 (5th Cir. 1973). These decisions, however, do not state that an inadequate warning can never give rise to liability for punitive damages. Moreover, these decisions are distinguishable on their facts. In each of these cases, defendant clearly warned against the particular hazardous use or effect of its product that had caused plaintiffs injuries. The inadequacies in the warnings were in detailing the extent of the hazard or describing the necessary precautions. In this case, on the other hand, defendant’s warning was inadequate both in failing to give details, and in failing to meaningfully inform Elastoplast users as to exactly what use was dangerous.

*400I would affirm the judgment in its entirety.