A worker who suffered serious injuries in 2017 after a 1,300-pound load of lighting fixtures fell onto him has lost the $41.9 million he was awarded by a jury in October 2022.
The Connecticut Appellate Court this week overturned the multimillion judgment against industrial lighting company Signify North America Corp. of Mounta
in Top, Pennsylvania. In its opinion dated June 2, the appeals court ruled that the trial court judge and jury wrongly concluded that Signify should have foreseen the injuries
that rendered Juan Cruz a paraplegic as a result of its failure to adequately secure the lights to a pallet for shipping.
Signify shipped the lights to wholesaler Rexel USA Inc. in Hartford, Connecticut where Cruz wor
ked without stretch-wrapping the lights onto the pallet as was its own and standard industry safety practice and part of its agreement with Rexel.
But even if it did not properly secure the lights, Signify could not have anticipated the conduct or
events at the warehouse for up to five days after the shipment was received that led up to Cruz’s injurie
s. “To hold otherwise would be to convert the imperfect vision of reasonable foreseeability into the perfect vision of hindsight,” the appellate court commented.
After receiving the shipment, Rexel placed the pallet on the top shelf of a storage rack in
its warehouse without stretch wrapping or further securing the lights. When a temporary staffer operating a reach truck made contact with the lights during a picking opera
tion, the lights slid off the pallet onto Cruz. Cruz experienced a traumatic spinal cord injury resulting in him becoming paraplegic; he will never walk again.
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Cruz was covered by Rexel’s workers’ compensation as the exclusive remedy vis-a-vis his employer.
Cruz and his wife sued Signify for negligence and loss of consortium. Cruz argued that his injuries were a reasonably foreseeable consequence of Signify’s presumed failure to secure the lights to the pallet with stretch wrap.
Signify filed a motion for summary judgment with the trial court claiming that it was not liable for negligence because Cruz’s workplace injuries were not
foreseeable, and, thus, it did not owe a duty of care to the Rexel employee.
Trial Court
The trial court denied summary judgment. In rejecting Signify’s foreseeability argument, the court reasoned that, while the specific facts of the case ma
y be unusual, the general nature of the injuries was entirely foreseeable and it is foreseeable that a pallet of lighting products might fall on someone if they ar
e not safely packaged for transportation to a warehouse, or for normal handling when they are in the warehouse. The judge found that it was also entirely foresee
able that lighting products might be placed on an upper storage shelf, as opposed to on the floor of the warehouse.
The case was tried before a jury over the course of three weeks in September and October 5, 2022.
The jury returned a verdict in favor of Cruz, which the court accepted the same day. The jury found that Signify failed to adequately supervise its employees and failed to ensure that the pallet was packed safely and securely. It found that this negligence was a proximate cause of Cruz’s injuries and losses. The jury determined that Cruz’s economic and noneconomic damages totaled $100 million. Later, the court reduced the damages to $41.9 million.
