New York Law Review

Tag: Manufacturer Liability

  • McLaughlin v. Mine Safety Appliances Co., 522 N.Y.S.2d 657 (1987): Proximate Cause and Adequacy of Warnings

    McLaughlin v. Mine Safety Appliances Co., 11 N.Y.2d 62 (1962)

    A manufacturer’s negligence is not the proximate cause of injury if an intermediary’s actions, such as failing to provide adequate warnings or misusing a product, break the chain of causation, unless the intermediary’s conduct was foreseeable.

    Summary

    McLaughlin sued Mine Safety Appliances (MSA) for burns received while using MSA’s heat blocks. The Appellate Division reversed a judgment in favor of McLaughlin, finding that any negligence by MSA was not the proximate cause of the injuries because Skippy, McLaughlin’s employer, had been warned by MSA. The Court of Appeals reversed, holding that the issue of whether Skippy adequately warned McLaughlin was contested, and the jury could have found MSA liable regardless of Skippy’s actions. The court remitted the case for consideration of other issues raised but not addressed by the Appellate Division.

    Facts

    McLaughlin suffered burns while using heat blocks manufactured by Mine Safety Appliances Co. (MSA). MSA sold the heat blocks to Skippy Ice Cream, McLaughlin’s employer. MSA provided warnings to Skippy regarding the proper use of the heat blocks. There was conflicting evidence as to whether Skippy communicated these warnings to McLaughlin.

    Procedural History

    McLaughlin sued MSA in Supreme Court, and the jury returned a verdict in favor of McLaughlin. MSA appealed to the Appellate Division, which reversed the judgment on the law and facts and dismissed the complaint, concluding that MSA’s negligence was not the proximate cause of McLaughlin’s injuries because Skippy had been warned. McLaughlin appealed to the Court of Appeals.

    Issue(s)

    Whether the Appellate Division erred in finding that MSA’s negligence was not the proximate cause of McLaughlin’s injuries, based on its conclusion that Skippy Ice Cream adequately warned McLaughlin about the use of the heat blocks.

    Holding

    Yes, because the issue of whether Skippy adequately warned McLaughlin was contested, and the jury could have found MSA liable irrespective of Skippy’s actions.

    Court’s Reasoning

    The Court of Appeals found that the Appellate Division erred in concluding that Skippy had warned McLaughlin. The court noted that the only evidence of such warnings came from an interested witness, the president of Skippy, which the jury could have chosen not to believe. The court emphasized that the jury could have found MSA liable regardless of whether Skippy adequately warned McLaughlin or negligently failed to do so. Therefore, the Appellate Division’s reversal based on a finding of no proximate cause was incorrect. The court reasoned that under the charge given by the trial court, the jury could have found Red Diamond liable irrespective of whether Skippy Ice Cream adequately warned the decedent or negligently failed to do so. Because the Appellate Division did not address other legal and factual contentions raised by MSA, the Court of Appeals remitted the case for further consideration. The court did not address any other issues beyond the proximate cause determination.

  • Robinson v. Reed-Prentice Div. of Package Mach. Co., 49 N.Y.2d 471 (1980): Manufacturer Liability After Product Modification

    Robinson v. Reed-Prentice Div. of Package Mach. Co., 49 N.Y.2d 471 (1980)

    A manufacturer is not liable under strict products liability or negligence when a product is substantially altered after it leaves the manufacturer’s control, and that alteration is the proximate cause of the plaintiff’s injuries.

    Summary

    Gerald Robinson, a plastic molding machine operator, was injured when his hand was caught in a machine manufactured by Reed-Prentice. His employer, Plastic Jewel, had modified the machine by cutting a hole in the safety gate to accommodate its production process. Robinson sued Reed-Prentice, alleging defective design. The New York Court of Appeals reversed a judgment in favor of Robinson, holding that Reed-Prentice was not liable because Plastic Jewel’s modification substantially altered the machine and was the proximate cause of the injury. The court emphasized that a manufacturer’s responsibility is limited to the condition of the product when it leaves their control, and they are not responsible for subsequent alterations that render a safe product dangerous. The court stated that imposing liability in this scenario would expand manufacturer’s duty beyond reasonable bounds.

    Facts

    Reed-Prentice manufactured a plastic molding machine and sold it to Plastic Jewel in 1965. The machine included a safety gate with interlocks to prevent operation when the gate was open, complying with state safety regulations. Plastic Jewel modified the machine by cutting a large hole in the Plexiglas portion of the safety gate to allow for continuous molding of beads on a nylon cord. Gerald Robinson, an employee of Plastic Jewel, was injured when his hand went through the hole and was caught in the machine’s molding area.

    Procedural History

    Robinson sued Reed-Prentice, who then impleaded Plastic Jewel. The case was submitted to the jury on strict products liability and negligence theories. The jury found in favor of Robinson, apportioning 40% liability to Reed-Prentice and 60% to Plastic Jewel. The Appellate Division reversed and ordered a new trial on damages unless Robinson stipulated to a reduced verdict, which he did. Reed-Prentice and Plastic Jewel appealed to the New York Court of Appeals.

    Issue(s)

    Whether a manufacturer can be held liable under strict products liability or negligence when a product is substantially modified by a third party after it leaves the manufacturer’s control, and the modification is the proximate cause of the plaintiff’s injuries.

    Holding

    No, because a manufacturer’s duty is limited to designing and producing a product that is safe when it leaves their control. Substantial modifications by a third party that render a safe product defective are not the manufacturer’s responsibility.

    Court’s Reasoning

    The Court of Appeals reasoned that a manufacturer’s duty is to design and produce a safe product at the time of sale. While manufacturers must consider foreseeable uses (and misuses) of a product in their design, they are not required to create products impossible to abuse or whose safety features cannot be circumvented. The court stated that imposing liability for modifications by third parties would expand the scope of a manufacturer’s duty beyond reasonable bounds. The court emphasized that the safety gate, as originally designed, would have prevented the accident. Plastic Jewel’s modification, not a defect in the original design, was the proximate cause of Robinson’s injuries.

    The court distinguished between defects existing at the time of manufacture and subsequent alterations. Quoting the Restatement (Second) of Torts § 402A, the court noted that a product is defective if, at the time it leaves the seller’s hands, it is “in a condition not reasonably contemplated by the ultimate consumer and is unreasonably dangerous for its intended use.” Because the machine was safe when it left Reed-Prentice, they could not be held liable.

    The court acknowledged the hardship for the injured plaintiff, who might be barred from suing his employer due to workers’ compensation laws. However, this did not justify imposing an unreasonable duty on manufacturers. The court concluded that “where the product is marketed in a condition safe for the purposes for which it is intended or could reasonably be intended, the manufacturer has satisfied its duty.”