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Tennessee Supreme Court limits failure-to-warn defense in cases

8/6/26

By: Donald Patrick Eckler

Product manufacturers have long relied on the principle that they generally are not responsible for hazards created by products they did not manufacture, sell, or distribute. While product liability law varies by state, a recent Tennessee Supreme Court decision serves as a reminder that courts may closely examine allegations involving the foreseeable misuse of otherwise safe products when those products are used together.

In Woodruff v. Ford Motor Company, the Tennessee Supreme Court addressed whether its earlier decision in Coffman v. Armstrong International, Inc. automatically barred a failure-to-warn claim arising from the combined use of products made by different manufacturers.

The case arose from a tragic automobile accident involving a child who was riding in a booster seat while using a seatbelt extender. The booster seat was manufactured by Dorel, while the seatbelt extender originated from Ford. The plaintiff alleged that both products were independently safe for their intended uses but that their combined use created a dangerous condition. The theory against Ford centered on an alleged failure to warn consumers not to use the seatbelt extender in conjunction with a child’s booster seat.

Ford argued that the claim was barred by the Tennessee Supreme Court’s 2021 decision in Coffman, which held that manufacturers are not liable for injuries resulting from products they did not manufacture, distribute, or sell. The Court of Appeals agreed and dismissed the claim. The Tennessee Supreme Court reversed.

Importantly, the Court did not hold that Ford owed a duty to warn. Instead, it held only that Coffman did not require dismissal as a matter of law. According to the Court, Coffman involved a different factual scenario: post-sale integration of asbestos-containing materials manufactured by others into otherwise non-defective equipment. In contrast, Woodruff involved allegations that two independently sound products, when used together, created a dangerous condition.

For claims professionals and product manufacturers, the decision highlights several important considerations.

First, Tennessee courts distinguish between cases involving a third party’s defective product and cases involving the foreseeable combined use of two non-defective products. That distinction can significantly impact duty-to-warn analyses and may limit the effectiveness of early dispositive motions.

Second, under Tennessee law, foreseeability continues to play a meaningful role in product liability litigation. Evidence that a manufacturer knew, or should have known, that consumers were using a product in a particular unintended manner may become central to defending failure-to-warn claims. Internal communications, prior incidents, consumer complaints, and post-sale investigations can all become critical evidence.

Third, manufacturers should periodically evaluate product warnings, instructions, and known misuse data. Even where a product is not defectively designed and performs safely for its intended purpose, plaintiffs increasingly focus on the adequacy of warnings addressing foreseeable misuse scenarios.

The ultimate merits of the plaintiff’s claim remain unresolved, but Woodruff demonstrates that courts may hesitate to adopt broad rules eliminating failure-to-warn claims at the summary judgment stage when the allegations involve foreseeable interactions between products. For manufacturers, insurers, and claims handlers, the decision underscores the importance of developing detailed factual records concerning product design, intended use, known misuse, warning history, and consumer behavior. Those facts may ultimately determine whether a failure-to-warn claim reaches a jury or is resolved before trial.

From a defense perspective, the case serves as an important reminder that product liability exposure often turns not only on how a product was designed, but also on how effectively manufacturers identify, study, and address foreseeable misuse in the real world.

For more information, please contact Donald Patrick Eckler at patrick.eckler@fmglaw.com or your local FMG attorney.

Information conveyed herein should not be construed as legal advice or represent any specific or binding policy or procedure of any organization. Information provided is for educational purposes only. These materials are written in a general format and not intended to be advice applicable to any specific circumstance. Legal opinions may vary when based on subtle factual distinctions. All rights reserved. No part of this presentation may be reproduced, published or posted without the written permission of Freeman Mathis & Gary, LLP.