The Eighth Circuit Court of Appeals recently held that a mower manufacturer is not under a duty to supply optional equipment as standard equipment on mowers that it manufactures. In Parks v. Ariens Company, 829 F.3d 655 (8th Cir. 2016) Timothy Parks died when the riding mower he was operating fell off the edge of an embankment and rolled over on top of him. His wife brought suit claiming that the defendant was negligent for failing to equip the machine with a roll over protection system (ROPS). A ROPS was offered as an optional feature by the manufacturer and the plaintiff contended that it should have been included as standard equipment on the mower in question. The district court entered summary judgment for the defendant and plaintiff appealed
The Court of Appeals found that Timothy Parks was actually thoroughly knowledgeable relating to the mower and its use and was actually aware that the ROPS was available. The court also found that there are normal uses of the power mower which are not unreasonably dangerous without a ROPS. The Court of Appeals applied the “Optional Equipment Doctrine” and said:
“Based on the undisputed facts, Ariens fulfilled any duty it had to Timothy Parks when it provided the ROPS as an optional feature for the 152Z mower and insured that he had the information necessary to make an informed choice” 829 F.3d at 661.