Donald E. Meadows, Jr., an employee at Maple Creek Mine in Bentley, Pa., was installing a longwall shield in a mine when a fitting in a shut-off valve in the shield struck him in the face. Meadows lost his right eye in the accident and filed a lawsuit against Anchor Longwall and Rebuild Inc., claiming the company had replaced the fitting that injured him as part of a refurbishing process at the mine. He sued the company for both negligence and strict product liability. The federal trial court dismissed the product liability claim, finding that Anchor Longwall and Rebuild did not sell a product.
Anchor Longwall and Rebuild asked the federal trial court to grant summary judgment for it before trial on the negligence claim, asserting that there was no evidence that the valve in Meadows's possession was the valve that caused his injuries. The court agreed with Anchor Longwall and Rebuild that there may have been a break in the chain of custody of the valve from the time of the accident to the time of the lawsuit, and that could draw the authenticity of the valve into question. The court noted, however, that it was undisputed that the longwall shield that Meadows was installing when the accident occurred was one of the shields refurbished by Anchor Longwall and Rebuild and that all the valves on the refurbished shields were replaced. Based on these facts, the court ruled that Meadows was entitled to a trial to determine if the valve that caused his injuries was the valve in his possession.