Rastelli v. Goodyear Tire & Rubber Co., 79 N.Y.2d 289 (1992)
A product may be deemed ‘not reasonably safe’ if marketed in a condition (like with a removable safety guard) that permits foreseeable uses creating an unreasonable risk of harm, even if the product can be used safely with the guard in place.
Summary
This case concerns a product liability claim against the manufacturer of a forklift. The plaintiff was injured while operating the forklift without an overhead safety guard, which was designed to be removable. The Court of Appeals held that summary judgment for the defendant was inappropriate because there were triable issues of fact as to whether the forklift, as marketed with the removable guard, was “not reasonably safe” for its intended or reasonably anticipated uses. The Court distinguished this case from one involving material alterations to a safety device, emphasizing evidence suggesting the forklift was designed for use without the guard.
Facts
The plaintiff, Rastelli, was injured while operating a forklift manufactured by the defendant, Goodyear Tire & Rubber Co.
The forklift was originally equipped with an overhead safety guard, but this guard was removable.
At the time of the accident, the forklift was being operated without the safety guard attached.
The plaintiff argued the forklift was defectively designed because it could be operated without the safety guard, creating a risk of injury.
Procedural History
The plaintiff sued Goodyear, alleging the forklift was defectively designed.
The Supreme Court granted summary judgment to the defendant, dismissing the claim.
The Appellate Division reversed, denying summary judgment and holding that triable issues of fact existed.
Goodyear appealed to the New York Court of Appeals.
Issue(s)
Whether the manufacturer of a forklift is entitled to summary judgment in a product liability case when the forklift was marketed with a removable safety guard and the injury occurred while the forklift was operated without the guard.
Whether the act of detaching a removable safety guard constitutes a material alteration that absolves the manufacturer of liability.
Holding
1. No, because there are triable issues of fact concerning whether the forklift, as marketed with the removable safety guard, was “not reasonably safe” for the uses intended or reasonably anticipated by the manufacturer.
2. No, because simply detaching a removable safety guard, unlike a material alteration destroying a safety feature, does not automatically absolve the manufacturer of liability where there is evidence the product was designed to be used without the guard.
Court’s Reasoning
The Court reasoned that a product can be considered “not reasonably safe” if it is marketed in a way that permits foreseeable uses that create an unreasonable risk of harm. The Court distinguished this case from Robinson v. Reed-Prentice Div., where the safety device was materially altered, destroying its functional utility. Here, there was evidence suggesting the forklift was purposefully manufactured to permit its use without the safety guard. The court stated that unlike the situation in Robinson, this case involved no “[m]aterial alterations…which work[ed] a substantial change in the condition in which the product was sold by destroying the functional utility of a key safety feature.” The court emphasized the presence of “evidence in this record that the forklift was purposefully manufactured to permit its use without the safety guard.” Therefore, the question of whether the forklift was reasonably safe for its intended uses was a question of fact for a jury to decide. The court implies that manufacturers have a duty to consider the safety implications of features they design into their products, especially when those features allow for the product’s use in a potentially dangerous manner. There were no dissenting or concurring opinions noted in the memorandum opinion.