Gonzalez v. Batavia Atomic Horseshoes, Inc., 79 N.Y.2d 965 (1992)
A defendant is not considered a regular seller of goods for the purposes of strict products liability if its sales of such goods are incidental to its primary business and involve equipment acquired mainly for internal use.
Summary
Gonzalez, injured while using a punch press, sued Batavia Atomic Horseshoes, Inc., the seller of the used press. The jury found Batavia liable under strict products liability as a regular seller of used goods. The New York Court of Appeals reversed, holding that Batavia’s limited and incidental sales of used machinery, primarily acquired for its own use, did not qualify it as a ‘regular seller’ for strict liability purposes. The court emphasized that Batavia’s primary business was horseshoe manufacturing, and the machinery transactions were infrequent and ancillary to that core business.
Facts
Batavia Atomic Horseshoes, Inc. primarily manufactured and sold horseshoes.
On three occasions, including the sale to Records Reserve Corp. (plaintiff’s employer), Batavia purchased used industrial machinery in lots.
Batavia intended to keep most of the machinery for its own manufacturing purposes.
The punch press sold to Records Reserve was never unloaded at Batavia’s facility.
It was sold directly off the truck from an auction and was at Batavia’s facility for about one hour before Records Reserve took delivery.
Procedural History
Plaintiff sued Batavia after being injured while operating the punch press.
The jury found Batavia liable under strict products liability.
Batavia appealed, arguing it was not a regular seller of used goods.
The Appellate Division affirmed the trial court’s finding of fact.
Batavia appealed to the New York Court of Appeals.
Issue(s)
Whether the evidence presented was sufficient to support a finding that Batavia Atomic Horseshoes, Inc. was a ‘regular seller’ of used goods for the purposes of strict products liability.
Holding
No, because Batavia’s sales of used industrial machinery were incidental to its primary business of manufacturing horseshoes and the machinery was mainly acquired for its own use. The transactions were not a regular part of its business.
Court’s Reasoning
The court emphasized that a factual finding affirmed by the Appellate Division is generally beyond the Court of Appeals’ review if supported by evidence. However, the court found that the evidence presented did not support the jury’s finding that Batavia engaged in sales of equipment as a “regular part of its business,” citing Sukljian v. Ross & Son Co., 69 NY2d 89, 95. The court noted that Batavia’s primary business was horseshoe manufacturing, and the machinery transactions were infrequent and ancillary. The court highlighted the fact that the punch press was never even unloaded at Batavia’s facility, underscoring the incidental nature of the transaction. The court stated: “Batavia’s business was the manufacture and sale of horseshoes. It had engaged in incidental transactions involving the purchase and resale of used industrial machinery on three occasions… In each transaction, it purchased used equipment in lots intending to keep much of the machinery for its own purposes.” Because the court determined that Batavia was not a regular seller of used goods as a matter of law, it did not reach the broader question of whether strict products liability applies to regular sellers of used goods, a question left open in Sukljian.