Rush, C.J.
In Indiana, when an individual is injured by a defectively designed product, the Indiana Product Liability Act (IPLA) provides a basis for relief. The injured party may bring a defective-design claim against the manufacturers of a component part, as well as of the final product.
Today we address a narrow question regarding an IPLA design-defect claim: when does a component-part manufacturer owe no duty, as a matter of law, to install safety features that an injured party alleges are necessary?
PACCAR is the manufacturer of a “glider kit,” a component part that becomes an operable over-the-road semi-truck after a purchaser installs an engine, transmission, and exhaust system. The glider kit has a forty-foot blind spot behind it; and it is PACCAR’s standard practice not to include certain safety features to mitigate that danger, unless a customer specifically requests them.
Here, a driver backed up a semi with an integrated PACCAR glider kit and struck and killed construction foreman Rickey Brewer. His widow asserted a design-defect claim against PACCAR, alleging that the lack of certain safety features rendered the glider kit defective. PACCAR argued that it was entitled to summary judgment because it owed no duty, as a matter of law, to install those safety features—because this duty fell solely on the final manufacturer of the completed semi.
Under these circumstances, PACCAR, as the component-part manufacturer, is not entitled to summary judgment. Its glider kit was not going to be incorporated into an end product that had multiple anticipated configurations. Rather, the component part had one reasonably foreseeable use: to be integrated into an operable over-the-road semi. Thus, PACCAR had to make one of two showings to be relieved of a duty, as a matter of law, to include the allegedly necessary safety features. It made neither.
PACCAR did not show that the final manufacturer was offered, and declined, the allegedly necessary safety features or that the integrated glider kit can be used safely without them. Thus, whether PACCAR owed Brewer a duty to include the features is a question for the trier of fact.
Finally, while PACCAR may assert a sophisticated-user defense against the design-defect claim, the merits of that defense are likewise a question for the trier of fact. We accordingly reverse the trial court’s grant of summary judgment for PACCAR.
…
I. In Indiana, component-part manufacturers may have a duty to include safety features under certain circumstances.
The IPLA establishes when a product is defective, including in design. Indiana Code section 34-20-4-1 provides…
….
We recognize that when a component part is integrated into an end product that has multiple anticipated configurations, a component-part manufacturer may have no duty, as a matter of law, to install safety features. But those are not the circumstances here. The designated evidence confirms that PACCAR’s component part—the glider kit—has one reasonably foreseeable use. And PACCAR has failed to show that it offered, and W&W rejected, the allegedly necessary safety features or that the integrated glider kit can be used safely without them. Rather, questions of material fact remain on these issues, making summary judgment in favor of PACCAR inappropriate.
A. Component-part manufacturers have no duty under the IPLA to install safety features when it is foreseeable that the final manufacturer will put the component to different uses depending on how it integrates the component into the final product—but this is not the case here.
….
Here, however, PACCAR has pointed to no anticipated end configuration that prevented it from reasonably knowing whether certain safety features related to the inevitable forty-foot blind spot should be included. The designated evidence indisputably shows that PACCAR’s sleeper-cab glider kit has one reasonably foreseeable use—to be combined with an engine, transmission, and exhaust system into an over-the-road semi. And there is no reasonable dispute that an over-the-road semi with a sleeper cab is, at some point, going to be used in reverse, and that the glider kit—both as supplied and as integrated—has a forty-foot blind spot. So unlike in Shanks and Del Signore, here multiple anticipated end configurations do not leave the component-part manufacturer without a duty, as a matter of law, to include safety features necessary to adequately abate inherent dangers.
But this does not mean that a manufacturer of a component part with one reasonably foreseeable use will necessarily owe a duty, as a matter of law, to include allegedly necessary safety features. Rather, the component-part manufacturer has two paths to relieve itself of such a duty. We examine those in detail below, applying them to the facts before us.
B. Component-part manufacturers have no duty under the IPLA to install safety features if they make one of two showings; PACCAR has made neither.
Existing precedent does not squarely address a component-part manufacturer’s duty to install safety features when the part has one reasonably foreseeable use. But we find instructive both federal caselaw and section 5 of the Restatement (Third) of Torts: Products Liability— commonly referred to as the “component parts doctrine,” see Davis v. Komatsu Am. Indus., 42 S.W.3d 34, 38 & n.6 (Tenn. 2001). Drawing from these sources, we conclude that a component-part manufacturer will have no duty, as a matter of law, to install safety features if it makes one of two showings: (1) the safety features were offered to, and declined by, the final manufacturer or (2) the integrated product can be used safely without the allegedly necessary safety features. Here, PACCAR has failed to make either showing.
….
Thus, PACCAR has not established that it has no duty, as a matter of law, to include the safety features Brewer alleges are necessary for the glider kit’s reasonably foreseeable use.
II. The sophisticated-user defense applies to IPLA defective-design claims for a lack of safety features
Last, we address a defense PACCAR has implicitly raised to challenge Brewer’s design-defect claim: the sophisticated-user defense. Until now, IPLA caselaw has addressed this defense only in connection with inadequate-warning claims. See, e.g., Smock Materials Handling Co. v. Kerr, 719 N.E.2d 396, 401, 403 (Ind. Ct. App. 1999); Nat. Gas Odorizing, Inc. v. Downs, 685 N.E.2d 155, 162–64 (Ind. Ct. App. 1997), trans. denied.
The sophisticated-user defense typically exempts a manufacturer from providing warnings about a product’s potential dangers when the users of the product are—or should be—already aware of them. See Nat. Gas Odorizing, 685 N.E.2d at 163. Because this defense focuses on the user’s actual or constructive knowledge of the danger, its applicability “is almost always a question for the trier of fact.” Id. at 164.
Today we find that, given certain similarities between inadequate-warning claims and design-defect claims, the sophisticated-user defense should also be available to challenge design-defect claims.
….
Here, PACCAR has asserted that glider kits are sold to and used by “sophisticated purchasers.” PACCAR also refers to W&W as a “sophisticated” commercial entity, a “sophisticated” final manufacturer, and a “sophisticated” customer. Those allegations essentially assert a sophisticated-user defense. But, as stated above, this defense is suited for the trier of fact, not for summary judgment. See id. And, so, PACCAR can make this argument to the trier of fact on Brewer’s claims for defective design and for inadequate warnings.
Conclusion
PACCAR’s designated evidence fails to establish that it had no duty, as a matter of law, to include certain blind-spot safety features on its glider kit. We therefore reverse the trial court’s grant of summary judgment to PACCAR and remand for proceedings consistent with this opinion.
David, Massa, Slaughter, and Goff, JJ., concur.