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Case Citations [i] (Spring 2026)

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                            THE AMERICAN


                              LAW INSTITUTE



                                    Spring 2026 Citations



                                       TORTS



Generally

N.D.Iowa, 2024. Cit. generally in disc. Buyer of a winch that retailer sold under its private-label brand
name sued retailer, alleging a design defect and other claims after his finger became entangled in the
winch and had to be amputated. This court denied in part retailer's motion for summary judgment,
holding that buyer's design-defect claim was not barred under an Iowa statute that immunized retailers
from strict liability solely from a design or manufacturing defect, because buyer's claim was for
negligence, rather than strict liability. The court noted that Iowa courts largely followed the
Restatements, adopting new Restatements shortly after they were published, and that, while Iowa courts
recognized strict liability for products claims, a product user could still proceed on a negligence theory
under the Restatement First of Torts and the Restatement Second of Torts, both of which provided that
the manufacturer of a dangerous product was liable for a failure to exercise reasonable care in the
product's manufacture and design. Wilson v. Harbor Freight Tools USA, Inc., 747 F.Supp.3d 1168,
1174.



      DIVISION  ONE.  INTENTIONAL HARMS TO PERSONS, LAND, AND CHATTELS

      CHAPTER 2. INTENTIONAL INVASIONS OF INTERESTS IN PERSONALITY

              TOPIC  4. THE INTEREST IN FREEDOM FROM CONFINEMENT

§ 35. False Imprisonment

C.A.11, 2025. Subsec. (1)(d) quot. in sup. Filipino seamen who worked on a cruise ship filed claims for
false imprisonment and intentional infliction of emotional distress against Florida-based employer that
owned the ship, alleging that employer took two months to repatriate them to the Philippines after the
ship's operations were suspended by the federal government during a pandemic. The district court
granted employer's motion to dismiss for failure to state a claim under maritime law. This court
affirmed, holding that seamen did not state a claim for the maritime tort of false imprisonment, because
they failed to allege that employer lacked the lawful authority to confine them to the ship. The court

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