Voss v. Black & Decker, 59 N.Y.2d 102 (1987)
A manufacturer can be held liable for injuries resulting from a defective product when the product is used for its intended purpose or for an unintended but reasonably foreseeable purpose.
Summary
In Voss v. Black & Decker, the New York Court of Appeals addressed the liability of a toy manufacturer for injuries sustained by a child struck by a part of the toy. The plaintiffs argued that the toy, a doll resembling a cartoon character known for throwing a shield, was defective due to its design and lack of adequate warnings. The court held that the plaintiffs presented sufficient evidence to raise a jury question as to whether the toy was defective and whether the misuse (throwing the detachable part) was reasonably foreseeable, given the character’s television portrayal. This case underscores the duty of manufacturers to consider foreseeable misuse when designing and marketing products, especially those intended for children.
Facts
The infant plaintiff was injured when struck in the eye by a detachable part of a “Voltron-Defender of the Universe” doll, thrown by another child. The doll was a replica of a television cartoon character who used a shield as a weapon. The detachable part was described as a spinning shield, blade, or star. The toy was marketed for children age four and older. The plaintiffs alleged the toy was defective because of improper design and inadequate warnings.
Procedural History
The plaintiffs instituted an action to recover for personal injuries. The defendant moved for summary judgment. The lower court denied the motion. The Appellate Division affirmed the denial of summary judgment. The Court of Appeals affirmed the Appellate Division’s order.
Issue(s)
Whether the plaintiff presented sufficient evidence to present a question for the jury as to whether the toy was defective and not reasonably safe for its intended use or reasonably foreseeable unintended use.
Holding
Yes, because the plaintiff submitted expert evidence that, based on customs and standards in the toy safety community, the detachable part was defective and that throwing the part was foreseeable because of the character’s extensive television exposure.
Court’s Reasoning
The court stated the established rule: “A manufacturer who sells a product in a defective condition is liable for injury which results to another when the product is used for its intended purpose or for an unintended but reasonably foreseeable purpose.” The court relied on expert evidence presented by the plaintiff. This evidence indicated that the detachable part was defective based on toy safety standards. The court emphasized the foreseeability of the misuse. It noted the television character’s frequent use of a similar object as a projectile. The court concluded that this evidence created a triable issue of fact. The jury had to determine whether the product was defective and whether the specific misuse was a reasonably foreseeable unintended use. The court implicitly emphasized the manufacturer’s responsibility to consider foreseeable misuse, particularly when designing toys for young children who may not fully understand the potential dangers. The absence of adequate warnings further contributed to the potential liability.