Alabama
How Anderson v. Owens-Corning Fiberglas Corp. applies in Alabama: state-specific rules, key cases, and bar exam notes for Torts — Products Liability (Failure to Warn).
Alabama law follows the principles established in Anderson v. Owens-Corning Fiberglas Corp. regarding products liability, particularly the failure to warn. In Alabama, manufacturers can be held liable for failing to provide adequate warnings if such warnings would have altered a user's behavior.
Under Alabama law, a manufacturer is liable for failure to warn when the product is unreasonably dangerous due to a lack of adequate warnings or instructions, and the failure to warn occurs even if the product is otherwise safe for use.
In Hollis, the court held that manufacturers must provide warnings about dangers that are not obvious to consumers, or they may be found liable for harm resulting from unheeded risks.
The court found that a failure to provide adequate warnings about a product's hazards can support a products liability claim even if the user had prior experience with the product.
McMillan emphasized that the standard of care in providing warnings is based on what an ordinary consumer would expect.
While federal law, particularly under the Restatement (Third) of Torts, emphasizes design and manufacturing defect standards alongside failure to warn claims, Alabama's approach places a stronger focus on the adequacy of warnings provided. Federal standards tend to offer more explicit guidance on what constitutes a failure to warn, whereas Alabama relies on a more flexible, consumer-expectation standard.
Failure to warn claims are a critical part of tort law in Alabama and frequently appear in the Alabama bar exam, particularly under products liability discussions.