Codling v. Paglia, 32 N.Y.2d 330 (1973)

The manufacturer of a defective product may be held liable under strict products liability to any person injured by the defect, including bystanders, if the defect was a substantial factor in causing the injury.

Summary

The New York Court of Appeals expanded the scope of products liability to include non-user bystanders injured by a defective product. Frank and Marcia Codling were injured when their car collided with a car driven by Christino Paglia. Paglia’s car crossed into their lane due to a defect in its power steering system. The jury found Chrysler, the manufacturer, liable for breach of implied warranty. The court held that manufacturers can be held strictly liable to anyone injured by a defect in their product, even if they are not the direct purchaser or user, provided the product was used as intended, the user could not have discovered the defect with reasonable care, and the injured party could not have prevented the injury with reasonable care.

Facts

On August 2, 1967, Christino Paglia was driving his Chrysler when it suddenly crossed a double line and collided with a car driven by Frank Codling, owned by Marcia Codling. Paglia had purchased the car four months prior and had not experienced any prior issues with steering. Paglia testified that he attempted to steer to the right but the steering system “locked on me or something.”

Procedural History

The Codlings sued Paglia and Chrysler for negligence and breach of warranty. Paglia cross-claimed against Chrysler. The Codlings settled with Paglia. Paglia also sued Chrysler for his own injuries and property damage. The jury found Chrysler not negligent but liable for breach of warranty, awarding damages to the Codlings and Paglia. The Appellate Division affirmed the Codling’s verdicts but reversed Paglia’s cross-claim. Both Paglia and Chrysler appealed.

Issue(s)

1. Whether a manufacturer’s liability for breach of implied warranty extends to non-user innocent bystanders injured by the defective product?
2. Whether contributory negligence is a defense to a claim for strict products liability in New York?

Holding

1. Yes, because the policy of protecting the public from injury resulting from misrepresentations outweighs outdated rules of law. The manufacturer is in the best position to ensure product safety and should bear the cost of injuries caused by defects.
2. Yes, because a plaintiff’s contributory fault is a defense to an action for strict products liability.

Court’s Reasoning

The court acknowledged the erosion of the privity requirement in products liability law, citing cases like Greenberg v. Lorenz and Goldberg v. Kollsman Instrument Corp. The court stated, “[T]he ultimate purpose in widening the scope of the warranty is to cast the burden on the manufacturer who put his product in the marketplace.” It noted that bystanders have less opportunity to detect defects than users. The court emphasized the complex nature of modern products, making it difficult for consumers to detect defects. The court reasoned that manufacturers are best positioned to ensure product safety and should bear the economic burden of injuries. The court established limitations to strict products liability, including proper intended use, the user’s ability to discover the defect, and the injured party’s ability to avert the damages with reasonable care.

The Court also determined that contributory negligence is a defense to strict products liability claims. The court reasoned that a plaintiff’s failure to exercise reasonable care, independent of the product defect, should be considered. The court remanded Paglia’s claim for a new trial to determine if his actions contributed to his injuries, separate from the defective steering mechanism.