Sprung v. MTR Ravensburg Inc., 99 N.Y.2d 468 (2003)

A custom manufacturer engaged in the regular course of its business can be held strictly liable for defects in products it manufactures for market sale, even if it is a one-time fabrication.

Summary

The New York Court of Appeals addressed whether a custom manufacturer of a retractable floor, VF Conner, Inc., could be held strictly liable for injuries caused by the floor’s alleged defect. Plaintiff, an assembler at General Electric, was injured when the floor collapsed. The Court held that Conner was not a “casual manufacturer” exempt from strict liability because it manufactured the floor for market sale in its regular course of business. The Court reasoned that custom fabricators, like other manufacturers, possess expertise, have the opportunity to ensure safety, and are better positioned to bear the costs of injuries from defective products.

Facts

Plaintiff, an assembler at General Electric (GE), was injured while working on a turbine shaft rotor suspended on the MTR Ravensburg lathe. The lathe was situated in a pit. A retractable floor, fabricated by VF Conner, Inc. (Conner), was intended to provide a working surface for assemblers. While the plaintiff and a coworker attempted to extend the retractable floor, the panels detached from the wall enclosure and fell, causing injury to the plaintiff.

Procedural History

Plaintiff sued MTR Ravensburg (the lathe manufacturer) and Conner (the floor fabricator), alleging strict products liability, negligence, and other causes of action. Conner sought summary judgment, arguing it was a “casual manufacturer.” MTR Ravensburg cross-moved for summary judgment. The Supreme Court denied both motions. The Appellate Division reversed, dismissing the complaint, concluding that GE’s improper maintenance was the sole cause and that Conner was a casual manufacturer. The Court of Appeals modified the Appellate Division order, reinstating the complaint against Conner.

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Issue(s)

1. Whether VF Conner, Inc., as a custom manufacturer of the retractable floor, qualifies as a “casual manufacturer” and is thus exempt from strict products liability.

2. Whether VF Conner, Inc. had a role in the alleged defective design of the floor.

Holding

1. No, because Conner manufactured the retractable floor for market sale in the regular course of its business, it is not a “casual manufacturer.”

2. Undetermined, because there are disputed issues of fact regarding Conner’s involvement in the design and installation of the allegedly defective product.

Court’s Reasoning

The Court reasoned that strict products liability is imposed on manufacturers because they possess expertise, have the opportunity to ensure product safety, and can better absorb the costs of injuries caused by defective products. These policy considerations apply to custom fabricators engaged in their regular business, even if they are producing a unique item.

The Court distinguished this case from cases involving “casual” or “occasional” sales that are incidental to the seller’s regular business, citing Sukljian v. Ross & Son Co., 69 N.Y.2d 89 (1986). It stated that the retractable floor was manufactured specifically for market sale to General Electric, making Conner subject to strict liability. The court noted that “[s]o long as the product was built for market sale in the regular course of the manufacturer’s business, as it was here, strict liability may apply.”