The U.S. Court of Appeals for the Eighth Circuit reversed a jury verdict that found CRC Industries, Inc. liable for a fatal car accident caused by a driver who was impaired after huffing difluoroethane gas from the company's computer duster product.
In *McDougall v. CRC Industries, Inc.* (8th Cir. 2026), the court ruled in favor of CRC Industries, overturning a district court decision that had denied the manufacturer's motion for judgment as a matter of law. The case stemmed from the tragic death of Cynthia McDougall, who was killed when struck by a driver who had been inhaling compressed gas from a CRC duster canister.
David McDougall, acting individually and as trustee for his deceased wife's next-of-kin, filed suit against CRC Industries in U.S. District Court for the District of Minnesota. The lawsuit alleged failure to warn and defective design under Minnesota state law, claiming the duster product was inherently dangerous and inadequately labeled regarding inhalation risks.
At trial, the jury reached a mixed verdict that initially appeared to favor the plaintiff. While jurors found that CRC's warning labels were adequate, they determined that the duster itself was defectively designed. This finding suggested the product posed unreasonable dangers even with proper warnings in place. The jury awarded damages to McDougall for his wife's wrongful death.
However, CRC Industries challenged the verdict through a post-trial motion for judgment as a matter of law under Federal Rule of Civil Procedure 50(a)(1). This procedural mechanism allows courts to overturn jury verdicts when there is insufficient evidence to support the finding. The district court denied CRC's motion, prompting the company to appeal to the Eighth Circuit.
Circuit Judge Kobes, writing for a three-judge panel that also included Judges Loken and Smith, applied the standard de novo review for motions for judgment as a matter of law. Under this standard, appellate courts view evidence in the light most favorable to the verdict winner while determining whether a "legally sufficient evidentiary basis" exists for the jury's decision.
The court applied Minnesota law in reviewing the case, as required in diversity jurisdiction cases where federal courts hear disputes between parties from different states. The Eighth Circuit referenced precedent from *Klingenberg v. Vulcan Ladder USA, LLC* (8th Cir. 2019) in establishing the appropriate review standard.
The appellate court ultimately concluded that CRC Industries was entitled to judgment as a matter of law, finding insufficient evidence to support the jury's determination that the duster was defectively designed. This reversal effectively eliminates McDougall's recovery and absolves CRC of liability for the fatal accident.
The case highlights complex questions surrounding product liability when consumer products are misused for intoxication purposes. Computer dusters containing difluoroethane are commonly sold for cleaning electronic equipment, but the compressed gas can produce euphoric effects when inhaled, a practice known as "huffing." This form of inhalant abuse can cause impairment, loss of consciousness, and sometimes death.
Manufacturers of products that can be misused for recreational intoxication face difficult legal terrain. While companies must warn consumers about foreseeable dangers, courts must balance public safety concerns against the principle that manufacturers should not be held liable for unintended criminal or reckless uses of their products.
The Eighth Circuit's decision suggests that adequate warnings may provide sufficient protection for manufacturers, even when products can be misused in dangerous ways. By finding CRC's warnings adequate while reversing the defective design finding, the court indicated that proper labeling can shield companies from liability when third parties misuse products and cause harm to others.
This ruling could have broader implications for how courts evaluate product liability claims involving inhalant abuse. The decision may encourage other manufacturers facing similar lawsuits to seek judgment as a matter of law when adequate warnings are present, arguing that proper labeling eliminates design defect liability.
For the McDougall family, the reversal represents a complete loss after initially prevailing at trial. The case demonstrates how appellate review can dramatically alter outcomes in complex product liability litigation, particularly when legal standards for defective design claims are disputed.
The ruling also underscores ongoing public health challenges related to inhalant abuse. While legal liability questions are resolved through court proceedings, the availability of household products for dangerous recreational use remains a persistent safety concern affecting communities nationwide.
CRC Industries successfully defended against claims that could have resulted in substantial damages and potentially broader changes to how duster products are designed, manufactured, or marketed. The Eighth Circuit's reversal provides the company with complete vindication after facing the prospect of significant liability for the tragic consequences of product misuse.