Cruz v. Spec Personnel, LLC

Syllabus

The defendant S Co. appealed from the trial court's judgment for the plain- tiffs, J and E, rendered following a jury trial. J sustained serious workplace injuries when an approximately 1300 pound load of lights, which had been sold and shipped by S Co. to J's employer, R Co., fell onto him. Following delivery to R Co., the lights, which had not been secured by stretch wrap to the pallet on which they had been delivered, were placed on the top shelf of a storage rack in a warehouse operated by R Co. The lights subsequently slid off the pallet onto J after a temporary staffer for R Co., while operating a reach truck, made contact with the lights. J's wife, E, claimed an attendant loss of consortium. S Co. claimed, inter alia, that the court, in denying its postverdict motion for judgment notwithstanding the verdict, improperly concluded that, as a product shipper, it owed a duty of care that extended to J and the type of harm he suffered in the postdelivery warehouse accident. Held: The trial court, in denying the defendant's postverdict motion for judgment notwithstanding the verdict, improperly determined that S Co. owed a duty of care to protect against J's workplace injuries, as J's workplace injuries were not a reasonably foreseeable consequence of S Co.'s presumed failure to secure the lights to the pallet by stretch wrap before they were shipped. Argued October 10, 2024—officially released June 2, 2026