adequacy warning (District of Columbia) · Go Syfert
← District of Columbia issues

adequacy warning in District of Columbia

11 District of Columbia opinions name it 1 courts 1968–2025 2 in the last five years

The cases below were cited by District of Columbia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
Cottam v. CVS Pharmacygreen
mass · 2002 · cited in 1 District of Columbia opinions naming this issue, 2025–2025
1 sentence

2025Akin to the adequacy of warnings in products liability cases, the key considerations for the jury are (1) the extent of the defendant’s undertaking to warn; (2) whether a reasonable person would have seen and understood the warning, see Cottam v. CVS Pharmacy, 764 N.E.2d 814, 823 (Mass. 2002); and (3) whether the warning was sufficient to apprise the individual of the specific danger ultimately encountered.

11
Fong v. City of Phoenixgreen
arizctapp · 2024 · cited in 1 District of Columbia opinions naming this issue, 2025–2025
2 sentences

2025The only question, then, is whether Red Coats’s placement of the wet floor sign—the general presence of which is undisputed—was reasonably calculated to protect passersby from the hazard created by mopping. 1 In other words, the question is whether the warning given was adequate. 1 It is not clear to us why the trial court believed the issue extended to what “further action” Red Coats should have taken beyond placing the wet floor sign. 7 In products liability cases, “[c]ourts generally hold that expert testimony is not required to determine the adequacy of warnings aimed at consumers and end

2025“Unlike manufacturer warnings aimed at prescribing physicians and other professionals with specialized knowledge, product safety warnings directed at lay people need only be reasonably readable and apprise a consumer exercising reasonable care of the existence and seriousness of the danger.” Id. at 1196 (internal quotation marks and ellipses omitted).

11
Rogers, Cosandra v. Ingersoll Rand Cogreen
cadc · 1998 · cited in 1 District of Columbia opinions naming this issue, 2008–2008
2 sentences

2008D.C. at 201, 144 F.3d at 844 ("Ingersoll-Rand’s proposed instruction does exactly what the District of Columbia Court of Appeals said was impermissible: it elevates the adequacy of its warnings to the sole consideration in the risk-utility analysis."). 12 .

2008Id., 330 U.S.App.

11
MacK v. United Statesgreen
dc · 1990 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
1 sentence

1993Witherspoon, supra, 557 A.2d at 590 ; Douglas, supra, 488 A.2d at 126 ; see Mack v. United States, 570 A.2d 777, 782 (D.C.1990).

11
Frank Borowicz v. Chicago Mastic Company, Frank Borowicz v. Chicago Adhesive Products Companygreen
ca7 · 1966 · cited in 1 District of Columbia opinions naming this issue, 1990–1990
1 sentence

1990We distinguished cases from other jurisdictions in which courts had held a label adequate as a matter of law based on two principles: contributory negligence as a matter of law by the plaintiff, see Moschkau v. Sears, Roebuck & Co., 282 F.2d 878 (7th Cir.1960), and the rule that “there is no duty to warn against a danger which is already known to the plaintiff,” Burch, supra, 366 A.2d at 1088 n. 25, citing Borowicz v. Chicago Mastic Co., 367 F.2d 751, 758 (7th Cir.1966) (“no one needs notice of what he already knows”). 6 The “experienced user” exception stems from *1120 the view enunciated in

11
Russell v. GAF Corp.green
dc · 1980 · cited in 1 District of Columbia opinions naming this issue, 1990–1990
2 sentences

1990Cf., Russell, supra, 422 A.2d at 992-94 (discussing adequacy of warning given to an intermediary). 13 .

1990Cf., Russell, supra, 422 A.2d at 992-94 (discussing adequacy of warning given to an intermediary). 13 .

11
Firestone v. Freilinggreen
ohctcompltuscar · 1963 · cited in 1 District of Columbia opinions naming this issue, 1989–1989
1 sentence

1989See, e.g., People v. Anglin, 6 Mich.App. 666 , 150 N.W.2d 532, 537 (1967) (absent an act of manifest bias, court must conduct investigation when allegation is made during trial to determine whether juror was prejudiced); United States v. Fay, 238 F.Supp. 1005, 1007 (S.D.N.Y.1965) (juror-initiated communication with counsel, if discovered during trial, would require inquiry regarding juror’s continued impartiality) (dictum); Firestone v. Freiling, 188 N.E.2d 91, 94 (Ohio 1963) (remedy for juror infirmity reported during trial is seating of alternate juror); cf. Smith v. Phillips, supra, 455 U.S

11
United States ex rel. Moore v. Faygreen
nysd · 1965 · cited in 1 District of Columbia opinions naming this issue, 1989–1989
1 sentence

1989See, e.g., People v. Anglin, 6 Mich.App. 666 , 150 N.W.2d 532, 537 (1967) (absent an act of manifest bias, court must conduct investigation when allegation is made during trial to determine whether juror was prejudiced); United States v. Fay, 238 F.Supp. 1005, 1007 (S.D.N.Y.1965) (juror-initiated communication with counsel, if discovered during trial, would require inquiry regarding juror’s continued impartiality) (dictum); Firestone v. Freiling, 188 N.E.2d 91, 94 (Ohio 1963) (remedy for juror infirmity reported during trial is seating of alternate juror); cf. Smith v. Phillips, supra, 455 U.S

11
People v. Anglingreen
michctapp · 1967 · cited in 1 District of Columbia opinions naming this issue, 1989–1989
2 sentences

1989See, e.g., People v. Anglin, 6 Mich.App. 666 , 150 N.W.2d 532, 537 (1967) (absent an act of manifest bias, court must conduct investigation when allegation is made during trial to determine whether juror was prejudiced); United States v. Fay, 238 F.Supp. 1005, 1007 (S.D.N.Y.1965) (juror-initiated communication with counsel, if discovered during trial, would require inquiry regarding juror’s continued impartiality) (dictum); Firestone v. Freiling, 188 N.E.2d 91, 94 (Ohio 1963) (remedy for juror infirmity reported during trial is seating of alternate juror); cf. Smith v. Phillips, supra, 455 U.S

1989See, e.g., People v. Anglin, 6 Mich.App. 666 , 150 N.W.2d 532, 537 (1967) (absent an act of manifest bias, court must conduct investigation when allegation is made during trial to determine whether juror was prejudiced); United States v. Fay, 238 F.Supp. 1005, 1007 (S.D.N.Y.1965) (juror-initiated communication with counsel, if discovered during trial, would require inquiry regarding juror’s continued impartiality) (dictum); Firestone v. Freiling, 188 N.E.2d 91, 94 (Ohio 1963) (remedy for juror infirmity reported during trial is seating of alternate juror); cf. Smith v. Phillips, supra, 455 U.S

11
Donald Dee Collier v. W. J. Estelle, Director, Texas Department of Correctionsgreen
ca5 · 1975 · cited in 1 District of Columbia opinions naming this issue, 1986–1986
1 sentence

1986See Collier v. Estelle, 506 F.2d 22, 23-24 (5th Cir.1975) (the waiver of the fundamental right to appeal requires knowing and intelligent participation by the defendant); United States ex. rel.

11
Ferebee v. Chevron Chemical Co.green
dcd · 1982 · cited in 1 District of Columbia opinions naming this issue, 1985–1985
2 sentences

1985Salem, supra, 370 U.S. at 35 , 82 S.Ct. at 1122 . 17 This is such a case, for there is “no question more appropriately left to a common sense lay judgment than that of whether a written warning gets its message across to an average person.” Fere-bee v. Chevron Chemical Co., 552 F.Supp. 1293, 1304 (D.D.C.1982). 18 It cannot be said that the trial court’s decision to exclude Decker’s testimony was clearly erroneous, and this ruling is therefore affirmed.

1985Co., 552 F.Supp. 1293, 1303 (D.D.C.1982). 13 .

11
cluster 332474green
ca5 · 1976 · cited in 1 District of Columbia opinions naming this issue, 1985–1985
1 sentence

1985It is true that the adequacy of warnings “cannot be evaluated apart from the knowledge and expertise of those who may reasonably be expected to use” the product, Martinez v. Dixie Carriers, Inc., 529 F.2d 457, 465 (5th Cir.1976).

11
Hardison v. Shirlington Trust Companygreen
dc · 1959 · cited in 1 District of Columbia opinions naming this issue, 1968–1968
2 sentences

1968Hardison v. Shirlington Trust Co., D.C.Mun.App., 148 A.2d 88, 90 (1959).

1968Hardison v. Shirlington Trust Co., D.C.Mun.App., 148 A.2d 88, 90 (1959).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in District of Columbia. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Washington Metropolitan Area Transit Authority v. Barksdale-Showell green
dc · 2009
1 sentence

2022In the court’s view, although sovereign immunity might protect WMATA 4 from a suit challenging the adequacy of warnings that are actually provided, this suit alleged an outright failure to provide any warnings because it was unclear whether passengers could even “see the yellow warning cone on the station platform when they exited the train.” For that reason, the court likened this case to one in which we held that sovereign immunity did not insulate WMATA from a failure-to-warn suit where WMATA provided no warnings and “did not provide a policy rationale for its decision not to warn.” WMATA v

12022–2022
Oxendine v. Merrell Dow Pharmaceuticals, Inc. green
dc · 1986
2 sentences

1994Liability in this case focussed on whether Bendectin caused appellee's birth defects, Oxendine I, supra, 506 A.2d at 1110 , not on the adequacy of the warnings.

1994Liability in this case focussed on whether Bendeetin caused appellee’s birth defects, Oxendine I, supra, 506 A.2d at 1110 , not on the adequacy of the warnings.

11994–1994
Douglas v. United States green
dc · 1985
2 sentences

1993Witherspoon, supra, 557 A.2d at 590 ; Douglas, supra, 488 A.2d at 126 ; see Mack v. United States, 570 A.2d 777, 782 (D.C.1990).

1993Witherspoon, supra, 557 A.2d at 590 ; Douglas, supra, 488 A.2d at 126 ; see Mack v. United States, 570 A.2d 777, 782 (D.C.1990).

11993–1993
Witherspoon v. United States green
dc · 1989
2 sentences

1993Witherspoon, supra, 557 A.2d at 590 ; Douglas, supra, 488 A.2d at 126 ; see Mack v. United States, 570 A.2d 777, 782 (D.C.1990).

1993Witherspoon, supra, 557 A.2d at 590 ; Douglas, supra, 488 A.2d at 126 ; see Mack v. United States, 570 A.2d 777, 782 (D.C.1990).

11993–1993
Emil H. Moschkau v. Sears, Roebuck and Company, a Foreign Corporation neutral
ca7 · 1960
1 sentence

1990We distinguished cases from other jurisdictions in which courts had held a label adequate as a matter of law based on two principles: contributory negligence as a matter of law by the plaintiff, see Moschkau v. Sears, Roebuck & Co., 282 F.2d 878 (7th Cir.1960), and the rule that “there is no duty to warn against a danger which is already known to the plaintiff,” Burch, supra, 366 A.2d at 1088 n. 25, citing Borowicz v. Chicago Mastic Co., 367 F.2d 751, 758 (7th Cir.1966) (“no one needs notice of what he already knows”). 6 The “experienced user” exception stems from *1120 the view enunciated in

11990–1990
Burch v. Amsterdam Corporation green
dc · 1976
2 sentences

1990In Burch v. Amsterdam Corp., supra, the progenitor of failure to warn decisions in this jurisdiction, we rejected the defendant’s argument that the adequacy of a warning label could be resolved as a matter of law in circumstances where the plaintiff was not an experienced user of a highly volatile flooring adhesive. 366 A.2d at 1088 n. 25.

1990We distinguished cases from other jurisdictions in which courts had held a label adequate as a matter of law based on two principles: contributory negligence as a matter of law by the plaintiff, see Moschkau v. Sears, Roebuck & Co., 282 F.2d 878 (7th Cir.1960), and the rule that “there is no duty to warn against a danger which is already known to the plaintiff,” Burch, supra, 366 A.2d at 1088 n. 25, citing Borowicz v. Chicago Mastic Co., 367 F.2d 751, 758 (7th Cir.1966) (“no one needs notice of what he already knows”). 6 The “experienced user” exception stems from *1120 the view enunciated in

11990–1990
Smith v. Phillips green
scotus · 1982
2 sentences

1989See, e.g., People v. Anglin, 6 Mich.App. 666 , 150 N.W.2d 532, 537 (1967) (absent an act of manifest bias, court must conduct investigation when allegation is made during trial to determine whether juror was prejudiced); United States v. Fay, 238 F.Supp. 1005, 1007 (S.D.N.Y.1965) (juror-initiated communication with counsel, if discovered during trial, would require inquiry regarding juror’s continued impartiality) (dictum); Firestone v. Freiling, 188 N.E.2d 91, 94 (Ohio 1963) (remedy for juror infirmity reported during trial is seating of alternate juror); cf. Smith v. Phillips, supra, 455 U.S

1989See, e.g., People v. Anglin, 6 Mich.App. 666 , 150 N.W.2d 532, 537 (1967) (absent an act of manifest bias, court must conduct investigation when allegation is made during trial to determine whether juror was prejudiced); United States v. Fay, 238 F.Supp. 1005, 1007 (S.D.N.Y.1965) (juror-initiated communication with counsel, if discovered during trial, would require inquiry regarding juror’s continued impartiality) (dictum); Firestone v. Freiling, 188 N.E.2d 91, 94 (Ohio 1963) (remedy for juror infirmity reported during trial is seating of alternate juror); cf. Smith v. Phillips, supra, 455 U.S

11989–1989
Salen v. United States Lines Co. green
scotus · 1962
2 sentences

1985Salem, supra, 370 U.S. at 35 , 82 S.Ct. at 1122 . 17 This is such a case, for there is “no question more appropriately left to a common sense lay judgment than that of whether a written warning gets its message across to an average person.” Fere-bee v. Chevron Chemical Co., 552 F.Supp. 1293, 1304 (D.D.C.1982). 18 It cannot be said that the trial court’s decision to exclude Decker’s testimony was clearly erroneous, and this ruling is therefore affirmed.

1985Salem, supra, 370 U.S. at 35 , 82 S.Ct. at 1122 . 17 This is such a case, for there is “no question more appropriately left to a common sense lay judgment than that of whether a written warning gets its message across to an average person.” Fere-bee v. Chevron Chemical Co., 552 F.Supp. 1293, 1304 (D.D.C.1982). 18 It cannot be said that the trial court’s decision to exclude Decker’s testimony was clearly erroneous, and this ruling is therefore affirmed.

11985–1985
District of Columbia v. Jones green
dc · 1982
2 sentences

1982App., 442 A.2d 512 (1982).

1982The majority in upholding the trial court’s grant of summary judgment against the District upon the obvious factual dispute over the adequacy of the hearing afforded appellee relies upon a concession by government counsel at oral argument that the “procedures” in this case did not differ from those followed by the Department in D.C. v. Jones, D.C.App., 442 A.2d 512 (1982).

11982–1982

Where else courts name it

TX 172 (1935–2026) NY 130 (1953–2026) CA 78 (1954–2026) IL 57 (1970–2026) WA 48 (1968–2026) PA 46 (1971–2023) IN 43 (1979–2024) FL 43 (1972–2026) NJ 31 (1955–2025) LA 31 (1954–2024) MI 27 (1963–2022) MA 25 (1974–2025) OH 24 (1974–2026) MN 22 (1984–2024) OR 21 (1943–2024) NV 21 (1983–2022) MS 20 (1969–2017) CO 16 (1976–2021) WI 15 (1972–2026) MO 15 (1958–2019) CT 14 (1950–2016) AZ 14 (1947–2024) AL 13 (1983–2013) KS 13 (1984–2026) NM 13 (1975–2015) AR 12 (1992–2022) TN 11 (1985–2022) DC 11 (1968–2025) UT 11 (1989–2024) GA 10 (1982–2025) IA 10 (1986–2014) DE 9 (1985–2023) KY 9 (1968–2024) RI 9 (2000–2026) MD 8 (1968–2012) OK 7 (1975–2010) ID 6 (1979–2013) AK 6 (1973–2018) VA 5 (1985–2026) VT 5 (1990–2026) ND 5 (1909–1997) NC 4 (1975–2012) WY 4 (1992–2019) WV 4 (1979–2018) SC 4 (1973–2008) ME 3 (1981–2013) HI 3 (1999–2007) MT 3 (2000–2010) VI 2 (2002–2005)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check