Robinson v. Reed-Prentice Div. of Package Mach. Co., 49 N.Y.2d 471 (1980)
A manufacturer is not liable under strict products liability or negligence when a product is substantially altered after it leaves the manufacturer’s control, and that alteration is the proximate cause of the plaintiff’s injuries.
Summary
Gerald Robinson, a plastic molding machine operator, was injured when his hand was caught in a machine manufactured by Reed-Prentice. His employer, Plastic Jewel, had modified the machine by cutting a hole in the safety gate to accommodate its production process. Robinson sued Reed-Prentice, alleging defective design. The New York Court of Appeals reversed a judgment in favor of Robinson, holding that Reed-Prentice was not liable because Plastic Jewel’s modification substantially altered the machine and was the proximate cause of the injury. The court emphasized that a manufacturer’s responsibility is limited to the condition of the product when it leaves their control, and they are not responsible for subsequent alterations that render a safe product dangerous. The court stated that imposing liability in this scenario would expand manufacturer’s duty beyond reasonable bounds.
Facts
Reed-Prentice manufactured a plastic molding machine and sold it to Plastic Jewel in 1965. The machine included a safety gate with interlocks to prevent operation when the gate was open, complying with state safety regulations. Plastic Jewel modified the machine by cutting a large hole in the Plexiglas portion of the safety gate to allow for continuous molding of beads on a nylon cord. Gerald Robinson, an employee of Plastic Jewel, was injured when his hand went through the hole and was caught in the machine’s molding area.
Procedural History
Robinson sued Reed-Prentice, who then impleaded Plastic Jewel. The case was submitted to the jury on strict products liability and negligence theories. The jury found in favor of Robinson, apportioning 40% liability to Reed-Prentice and 60% to Plastic Jewel. The Appellate Division reversed and ordered a new trial on damages unless Robinson stipulated to a reduced verdict, which he did. Reed-Prentice and Plastic Jewel appealed to the New York Court of Appeals.
Issue(s)
Whether a manufacturer can be held liable under strict products liability or negligence when a product is substantially modified by a third party after it leaves the manufacturer’s control, and the modification is the proximate cause of the plaintiff’s injuries.
Holding
No, because a manufacturer’s duty is limited to designing and producing a product that is safe when it leaves their control. Substantial modifications by a third party that render a safe product defective are not the manufacturer’s responsibility.
Court’s Reasoning
The Court of Appeals reasoned that a manufacturer’s duty is to design and produce a safe product at the time of sale. While manufacturers must consider foreseeable uses (and misuses) of a product in their design, they are not required to create products impossible to abuse or whose safety features cannot be circumvented. The court stated that imposing liability for modifications by third parties would expand the scope of a manufacturer’s duty beyond reasonable bounds. The court emphasized that the safety gate, as originally designed, would have prevented the accident. Plastic Jewel’s modification, not a defect in the original design, was the proximate cause of Robinson’s injuries.
The court distinguished between defects existing at the time of manufacture and subsequent alterations. Quoting the Restatement (Second) of Torts § 402A, the court noted that a product is defective if, at the time it leaves the seller’s hands, it is “in a condition not reasonably contemplated by the ultimate consumer and is unreasonably dangerous for its intended use.” Because the machine was safe when it left Reed-Prentice, they could not be held liable.
The court acknowledged the hardship for the injured plaintiff, who might be barred from suing his employer due to workers’ compensation laws. However, this did not justify imposing an unreasonable duty on manufacturers. The court concluded that “where the product is marketed in a condition safe for the purposes for which it is intended or could reasonably be intended, the manufacturer has satisfied its duty.”