The U.S. Court of Appeals for the Seventh Circuit partially reversed a district court ruling Tuesday, allowing a product liability lawsuit against The Toro Company to proceed to trial after a woman lost her left leg below the knee in a riding lawnmower accident.
In *Hillman v. The Toro Company* (7th Cir. 2026), the appeals court held that expert testimony regarding the lack of an independent brake system on the mower creates genuine disputes of material fact that must be resolved by a jury. The court reversed summary judgment on strict products liability and negligent design claims based on the independent brake theory while affirming the district court's exclusion of other expert evidence.
Rebekah Hillman suffered the catastrophic injury while operating a Toro riding lawnmower. Hillman, along with her wife Jennifer Hillman and their minor daughter P.J.H., filed suit against Toro alleging multiple design defects. The plaintiffs argued the mower should have included a mechanical brake independent of the hydrostatic transmission, an interlock ignition system, or a rollover protection system for rider safety.
The U.S. District Court for the Central District of Illinois initially granted summary judgment to Toro after excluding all of the Hillmans' expert evidence as unreliable or irrelevant under Federal Rule of Evidence 702. Chief Judge Sara Darrow found that the plaintiffs' experts failed to meet the reliability standards established in *Daubert v. Merrell Dow Pharmaceuticals*.
On appeal, the Seventh Circuit panel consisting of Circuit Judges Frank Easterbrook, David Hamilton, and Candace Jackson-Akiwumi examined each category of expert testimony. Writing for the court, Judge Hamilton noted that while the district court properly excluded most expert evidence, it failed to directly address one expert's opinions regarding the independent brake system.
"Those opinions are reliable and relevant, and the expert's qualifications are unchallenged," Judge Hamilton wrote in the Jan. 21 opinion. "Those opinions raise genuine disputes of material facts on the independent brake theory."
The case involves zero-radius-turn mowers, a type of riding mower that can pivot in place for enhanced maneuverability around obstacles. These mowers typically use hydrostatic transmissions that allow the operator to control speed and direction through lever or steering wheel movements.
The Hillmans' theory centered on the absence of a traditional mechanical brake system separate from the hydrostatic transmission. Their expert argued that such an independent brake would have prevented the accident by providing an additional stopping mechanism when the primary transmission controls failed or proved inadequate.
Toro defended its design choices, arguing that the hydrostatic transmission system provides adequate stopping power when properly operated. The company maintained that additional safety features were unnecessary and that the accident resulted from operator error rather than design deficiency.
The appeals court's decision reflects the complex interplay between expert testimony standards and product liability law. Under Rule 702, courts must ensure that expert testimony is based on reliable scientific principles and will assist the trier of fact. The *Daubert* standard requires judges to act as gatekeepers, excluding unreliable expert opinions while allowing those that meet basic reliability thresholds.
Judge Hamilton's opinion distinguished between the various expert theories presented by the Hillmans. While affirming exclusion of testimony regarding interlock ignition systems and rollover protection, the court found that the independent brake expert's opinions met the reliability standard.
The ruling demonstrates how appellate courts review district court evidentiary decisions under an abuse of discretion standard. The Seventh Circuit found that while the district court properly excluded most expert evidence, it erred by not adequately considering the independent brake testimony's reliability and relevance.
The decision has implications for product liability litigation involving complex machinery and expert testimony standards. It reinforces that courts must carefully examine each expert opinion individually rather than making blanket exclusions based on case themes.
For the Hillman family, the partial reversal provides an opportunity to present their independent brake theory to a jury. The case will return to the district court for trial proceedings on the remaining claims.
The ruling also highlights ongoing debates in product liability law about manufacturer obligations to incorporate additional safety features. While manufacturers generally have broad discretion in design choices, they can face liability when feasible alternative designs would have prevented injuries.
The case number is 24-2865, and the appeal arose from Central District of Illinois case number 4:21-cv-04081-SLD-JEH. The Seventh Circuit heard oral arguments on Sept. 11, 2025, before issuing its decision Jan. 21, 2026.
The remanded case will now proceed to trial on the strict products liability and negligent design claims based on the independent brake theory, while Toro prevailed on all other theories of liability advanced by the plaintiffs.