Medina v. Louisville Ladder, Inc.

Arnaldo Medina (plaintiff) injured his elbow when he fell from a collapsed fold-down ceiling-mounted attic ladder. Medina and his friend, both Spanish speakers, had improperly installed the ladder, failing to trim its legs flush with the floor as required by the ladder’s instructions. Because the ladder’s legs were not flush with the floor, gaps existed at the ladder’s joints when in use, putting pressure on the hinges. Medina and his friend could not read English and did not read the ladder’s instructions, which were printed in only English. Medina and his wife, Luz Lopez (plaintiff), sued Louisville Ladder, Inc. and Home Depot U.S.A., Inc. (collectively, the ladder companies) (defendants), the manufacturer and seller of the ladder, respectively, in federal district court. Medina and Lopez alleged that the ladder companies’ product instructions and warnings were deficient under theories of negligence and strict liability because the installation instructions and safety warnings were exclusively written in English. Medina and Lopez claimed that bilingual product instructions were required because Home Depot advertised in English and Spanish in the state of Florida, a state with a 20 percent Hispanic population. Medina and Lopez also claimed that because Louisville Ladder issued product instructions in multiple languages to assemblers and purchasers in different countries, it should also do so in Florida. The ladder companies filed a motion for summary judgment with the district court, claiming the ladder was not unreasonably dangerous and that they were not negligent in failing to provide Spanish instructions and warnings.