Background
Joshua Glasscock sued Sig Sauer, Inc., alleging that the P320 handgun was defective due to its lack of a manual safety, light trigger pull, and immediate firing capability. Glasscock sought to represent a class of Missouri purchasers who bought the pistol without an external thumb safety. He admitted he had never inadvertently discharged the weapon or experienced any issues with it. Sig Sauer appealed the district court’s grant of class certification, arguing Glasscock lacked standing.
The court’s reasoning
The Eighth Circuit applied the manifest defect rule, requiring a product-defect plaintiff to show that the alleged defect has manifested itself to satisfy the injury-in-fact requirement of Article III standing. The court found that Glasscock’s admission that he had no issues with his P320 meant he failed to show a concrete injury. The court rejected arguments that the universal design defect created an inherent danger sufficient for standing, noting that the risk of inadvertent discharge had not materialized. The court also dismissed the benefit-of-the-bargain theory as speculative. Citing Johannessohn and Zurn, the court clarified that ownership of a product at risk of defect does not confer standing.
A product-defect plaintiff like Glasscock must show that he owns a product in which the alleged defect has manifested itself to meet the injury-in-fact requirement for Article III standing.
Glasscock v. Sig Sauer, Inc., No. 25-2707 (8th Cir. July 16, 2026)
What it means going forward
The decision reinforces the manifest defect rule in the Eighth Circuit, preventing product liability class actions from proceeding based solely on the existence of a design defect without proof of actual injury or manifestation of that defect.