Maryland

Enright v. Eli Lilly & Co. in Maryland Law

How Enright v. Eli Lilly & Co. applies in Maryland: state-specific rules, key cases, and bar exam notes for Torts.

State Approach

Maryland law follows a strict liability standard in tort cases for defective products, aligning with traditional interpretations of consumer protection. The courts focus primarily on whether the product is unreasonably dangerous to users when consumed as intended.

State Rule
In Maryland, a manufacturer or seller can be held strictly liable for a product defect if the defect makes the product unreasonably dangerous and the product was used as intended.
Significant State Cases

Puckett v. Treadway

The court held that a manufacturer could be held liable under strict liability for a defective product that causes injury when it is used as intended.

Boston Scientific Corp. v. McCoy

The court ruled that expert testimony is not always required to establish a product was defectively designed and unreasonably dangerous.

Clark v. McDonald’s Corp.

The court determined that the presence of a defect in the product was sufficient to establish liability, without needing evidence of negligence.

Comparison to Federal Law

In federal court, the strict liability standard may also consider factors such as the consumer's expectations or the use of risk/benefit analysis. Maryland courts, however, emphasize a more straightforward application of strict liability, focusing on the danger posed by the defect.

Bar Exam Note

Strict liability for product defects, as outlined in Enright, is a key concept tested in the Maryland bar exam, particularly relating to the responsibilities of manufacturers and sellers.

Practice Pointers
  • Always evaluate whether the product was used as intended to establish strict liability.
  • Consider the state's consumer expectation test versus other potential tests for product defects.
  • Pay attention to the nature of evidence required; expert testimony may not always be necessary.

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