Products Liability Law Reporter

The Eleventh Circuit Court of Appeals held that Carnival Corp. was not liable under a strict products liability theory for the improper design of a fire safety door threshold on its cruise ship.

Here, while taking a cruise on the Carnival Vista, Debra Roberts walked down a corridor and tripped over a fire safety door threshold, a metal strip running across the width of the corridor to support a fire screen door. She sued Carnival Corp., alleging strict liability and other claims. The district court granted summary judgment to the defense, holding, in part, that there was no evidence that Carnival had participated in, approved of, or designed the threshold.

Affirming, the court reasoned that although Carnival had filed a warranty claim regarding the thresholds at the fire safety doors on the Vista, there is no evidence the company had participated in any way in the design and manufacture of the thresholds or that the company had approved the thresholds’ design. The court rejected the plaintiff’s argument that because Carnival had accepted the Vista after its thresholds were modified, this constitutes approval of the thresholds’ design. The fact that the defendant had submitted a warranty claim does not create an issue of fact on this matter, the court said.

Consequently, the court held that summary judgment was proper.

Citation: Roberts v. Carnival Corp., 2022 WL 2188010 (11th Cir. June 17, 2022).