consumer expectation test (Florida) · Go Syfert
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consumer expectation test in Florida

6 Florida opinions name it 2 courts 1981–2025 1 in the last five years

The cases below were cited by Florida 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 (9)

CaseFollowedCited
Cassisi v. Maytag Co.green
fladistctapp · 1981 · cited in 3 Florida opinions naming this issue, 2004–2007
2 sentences

2007Id. at 1145 (footnotes omitted).

2004Searle & Co., 576 So.2d 728, 733 (Fla. 2d DCA 1991) (the test weighs a product's benefits against its known risks); Cassisi v. Maytag Co., 396 So.2d 1140, 1145 (Fla. 1st DCA 1981) (the test weighs the utility of the design versus the magnitude of the inherent risk). [5] In 1973, this Court adopted the comparative negligence doctrine in place of the contributory negligence doctrine.

23
Force v. Ford Motor Co.green
fladistctapp · 2004 · cited in 2 Florida opinions naming this issue, 2007–2020
2 sentences

2020See, e.g., Force v. Ford Motor Co., 879 So. 2d 103 , 109– 10 (Fla. 5th DCA 2004) (concluding that while “there may indeed be products that are too complex for a logical application of the consumer- expectation standard[,]” the consumer expectation standard nonetheless applied to seat belts, which were “on the cusp” of being “too complex for an ordinary consumer to have any expectations concerning their proper operation”); Tillman v. C.R.

2007See Force v. Ford Motor Co., 879 So.2d 103, 106-07 (Fla. 5th DCA 2004).

22
William P. Aubin v. Union Carbide Corporationgreen
fla · 2015 · cited in 2 Florida opinions naming this issue, 2020–2025
2 sentences

2025See Aubin v. Union Carbide Corp., 177 So. 3d 489, 503 (Fla. 2015) (“Th[e] [consumer expectations] test intrinsically recognizes that a manufacturer plays a central role in establishing the consumers’ expectations for a particular product, which in turn motivates consumers to purchase the product.”); Liggett Grp., Inc. v. Davis, 973 So. 2d 467, 478 (Fla. 4th DCA 2007) (Warner, J., specially concurring) (“[W]e look to the consumer expectation test to determine strict liability . . . .

2020Notably, Aubin v. Union Carbide Corp., 177 So. 3d 489 (Fla. 2015), did not categorically disapprove of the risk-benefit test.

12
LEGGETT GROUP, INC. v. Davisgreen
fladistctapp · 2007 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025See Aubin v. Union Carbide Corp., 177 So. 3d 489, 503 (Fla. 2015) (“Th[e] [consumer expectations] test intrinsically recognizes that a manufacturer plays a central role in establishing the consumers’ expectations for a particular product, which in turn motivates consumers to purchase the product.”); Liggett Grp., Inc. v. Davis, 973 So. 2d 467, 478 (Fla. 4th DCA 2007) (Warner, J., specially concurring) (“[W]e look to the consumer expectation test to determine strict liability . . . .

11
Tillman v. C.R. Bard, Inc.green
flmd · 2015 · cited in 1 Florida opinions naming this issue, 2020–2020
1 sentence

2020Bard, Inc., 96 F. Supp. 3d 1307, 1339 (M.D.

11
Standard Jury Inst.-Civil Cases (No. 02-2)green
fla · 2004 · cited in 1 Florida opinions naming this issue, 2007–2007
1 sentence

2007See Standard Jury Instructions—Civil Cases, 872 So.2d 893 (Fla.2004).

11
Adams v. GD Searle & Co., Inc.green
fladistctapp · 1991 · cited in 1 Florida opinions naming this issue, 2004–2004
1 sentence

2004Searle & Co., 576 So.2d 728, 733 (Fla. 2d DCA 1991) (the test weighs a product's benefits against its known risks); Cassisi v. Maytag Co., 396 So.2d 1140, 1145 (Fla. 1st DCA 1981) (the test weighs the utility of the design versus the magnitude of the inherent risk). [5] In 1973, this Court adopted the comparative negligence doctrine in place of the contributory negligence doctrine.

11
Soule v. General Motors Corp.green
cal · 1994 · cited in 1 Florida opinions naming this issue, 2004–2004
2 sentences

2004Their argument is summed up by the following passage from the appellees' answer brief: Perhaps the most significant problem with the consumer-expectations test is *109 that an ordinary consumer of a complex product like an automobile "simply has `no idea' how it should perform in all foreseeable situations, or how safe it should be made against all foreseeable hazards." Soule v. General Motors, 8 Cal.4th 548 , 34 Cal.Rptr.2d 607 , 882 P.2d 298, 308 (1994).

2004Their argument is summed up by the following passage from the appellees' answer brief: Perhaps the most significant problem with the consumer-expectations test is *109 that an ordinary consumer of a complex product like an automobile "simply has `no idea' how it should perform in all foreseeable situations, or how safe it should be made against all foreseeable hazards." Soule v. General Motors, 8 Cal.4th 548 , 34 Cal.Rptr.2d 607 , 882 P.2d 298, 308 (1994).

11
Phipps v. General Motors Corp.green
md · 1976 · cited in 1 Florida opinions naming this issue, 1981–1981
2 sentences

1981See Phipps v. General Motors Corp., 278 Md. 337 , 363 A.2d 955 (1976); Barker v. Lull Engineering Co., supra, note 8; Caterpillar Tractor Co. v. Beck, 593 P.2d 871 (Alaska 1979).

1981See Phipps v. General Motors Corp., 278 Md. 337 , 363 A.2d 955 (1976); Barker v. Lull Engineering Co., supra, note 8; Caterpillar Tractor Co. v. Beck, 593 P.2d 871 (Alaska 1979).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
In Re Fosamax Products Liability Litigation green
nysd · 2010
1 sentence

2020Litig., 742 F. Supp. 2d 460 , 470 n.4 (S.D.N.Y. 2010) (applying Florida law and concluding that “prescription pharmaceuticals are too complex for the straight-forward application of the consumer expectation test”).

12020–2020
Engle v. Liggett Group, Inc. green
fla · 2006
1 sentence

2007I do not agree with Judge Gross, however, that Engle v. Liggett Group, Inc., 945 So.2d 1246 (Fla.2006), gave a "green light" to strict liability design defect claims.

12007–2007
Scheman-Gonzalez v. Saber Mfg. Co. green
fladistctapp · 2002
1 sentence

2004A Florida case called to our attention by Ford and Mazda is Scheman-Gonzalez v. Saber Manufacturing Co., 816 So.2d 1133 (Fla. 4th DCA 2002).

12004–2004
Zimmer, Inc. v. Birnbaum green
fladistctapp · 2000
1 sentence

2004First, the proposal updates the case law cited for definitions of the term "unreasonably dangerous." Second, the proposal provides a caution regarding potential two-issue rule problems [2] that might arise if a *894 jury is instructed under PL 5 on both the consumer-expectation test [3] and the risk-utility test. [4] See Zimmer, Inc. v. Birnbaum, 758 So.2d 714 (Fla. 4th DCA 2000).

12004–2004
Fremaint v. Ford Motor Co. green
prd · 2003
1 sentence

2004From the automobile in general, the court interpolated to seatbelts in particular, and said that "Ordinary consumers are ill-equipped to decide what minimum safety to expect from seatbelts once a vehicle is involved in an accident, as manufacturers cannot warranty against all foreseeable injuries caused inside properly working vehicles." Id. at 30 .

12004–2004
Caterpillar Tractor Co. v. Beck green
alaska · 1979
1 sentence

1981See Phipps v. General Motors Corp., 278 Md. 337 , 363 A.2d 955 (1976); Barker v. Lull Engineering Co., supra, note 8; Caterpillar Tractor Co. v. Beck, 593 P.2d 871 (Alaska 1979).

11981–1981

Where else courts name it

CA 42 (1983–2026) IL 37 (1990–2026) OH 19 (1985–2025) WA 11 (1989–2024) TN 11 (1996–2021) CT 8 (1997–2019) AZ 6 (1985–2024) FL 6 (1981–2025) CO 5 (1986–2022) PA 5 (1981–2025) MD 4 (1988–2004) TX 4 (1980–2015) KS 4 (1982–1984) OR 3 (1995–2021) HI 3 (1994–2025) MO 3 (1986–2008) NV 2 (2017–2017) NJ 2 (1988–1996) DC 2 (1995–2013) LA 2 (1989–1994)

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.

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