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Hoon v. Lightolier
State: Maryland
Court: Court of Appeals
Docket No: 2596/02
Case Date: 09/15/2004
Preview:REPORTED IN THE COURT OF SPECIAL APPEALS OF MARYLAND No. 2596 September Term, 2002 _______________________________

DAVID HOON, ET AL.

V.

LIGHTOLIER, A DIVISION OF GENLYTE THOMAS GROUP, LLC

_______________________________ Salmon, Krauser, Barbera, JJ. _______________________________ Opinion by Salmon, J. Filed: September 15, 2004

This is a products liability case by homeowners and their insurer against the manufacturer of a light fixture. The fixture,

as one of its component parts, had a safety device that was designed to make the light blink on and off if the insulation in the immediate vicinity of the fixture got too hot. Alternating the electric current in this manner lowered the temperature emitted by the lightbulb and warned users of the problem. The fixture was accompanied by a label telling the installers of the fixture not to place insulation within three inches of it. The installer of the fixture failed to heed the warning. As a

result, heat from the fixture was entrapped, and the insulation ignited, causing a devastating fire. To complicate matters, the

safety device, because of either a manufacturing defect and/or negligent design, did not operate properly, and the lights never blinked. In litigation that followed, the owners of the home

damaged by the fire contended that their property loss had two concurrent causes: (1) the failure of the installer of the light fixture to abide by the manufacturer's warning and (2) the failure of the safety device to prevent the fire due to its negligent manufacture and/or defective design. Summary judgment was entered in the Circuit Court for Kent County in favor of the manufacturer of the light fixture. One of

the grounds for summary judgment was that (purportedly) the sole proximate cause of the fire was the failure of the installer of the light fixture to heed the manufacturer's warning. The motions

judge rejected the argument that the negligent manufacture and/or design of the safety device was a concurrent cause of the fire. The major issue presented in this appeal is whether the motions judge was legally correct in granting summary judgment on the ground that the third party's failure to heed the

manufacturer's warning was the sole proximate cause of the fire. I. FACTUAL SUMMARY1

Due to fire damages mentioned above, David and Texie Hoon ("the Hoons") and their insurer, Federal Insurance Company, brought suit in the Circuit Court for Kent County against Lightolier, a Genlyte Thomas Company, LLC ("Lightolier"), and others. Lightolier is the manufacturer of light fixtures, which were installed by Gede Installation, LLC ("Gede"), in the Chestertown,

1 Because the issue presented is whether the motions judge erred in granting summary judgment, the facts set forth in Part I of this opinion are recounted in the light most favorable to the parties that lost below, i.e., David and Texie Hoon ("the Hoons") and their insurer, Federal Insurance Company. See Md. Rule 2-501(e). Some of those facts are disputed by the appellee
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