After valve failed on child’s hair spray, minor attempted to cut open can of hair spray.


Child was standing in the kitchen near a gas stove when she opened the can. The can released a cloud of hair spray which was ignited by stove’s pilot light, severely burning the child. The child sued the hair spray manufacturer on the grounds that the warnings were inadequate and the hair spray was defectively designed with a flammable solvent. Court found that lower court implicitly ruled that product was defective under risk/utility analysis when court sent case to jury.[20]