Monday, March 25, 2013

Denny v. Ford Motor Company case brief

Denny v. Ford Motor Company case brief
639 N.Y.S.2d 250 (N.Y. 1995)


SYNOPSIS:
Pursuant to N.Y. Const. art. VI, § 3(b)(9) and N.Y. Comp. Codes R. & Regs. tit. 20, § 500.17, several questions regarding strict products liability and breach of implied warranty were certified concerning plaintiff injured party's products liability action, involving claims of negligence, strict products liability, and breach of implied warranty of merchantability, against defendant automobile manufacturer.

FACTS:
-June 9, 1986 accident in which plaintiff Nancy Denny was severely injured when the Ford Bronco II that she was driving rolled over.
-The rollover accident occurred when Denny slammed on her brakes in an effort to avoid a deer that had walked directly into her motor vehicle's path.

OVERVIEW: Upon its considerations of the issues raised by the parties, the court addressed the following certified questions: (1) whether the strict products liability claim and the breach of implied warranty of merchantability claim were identical; (2) whether, if the claims were different, the strict products liability claim encompassed the implied warranty claim; and (3) whether, if the claims were different, the jury's finding of no product defect was reconcilable with its finding of breach of warranty.

HOLDING:
The court found that under the relevant state law, the factual judgments would lead to the concomitant legal conclusion that injured party's strict product liability cause of action was not viable but that automobile manufacturer was nonetheless liable for breach of its promise that the vehicle was "merchantable" or "fit" for its "ordinary purposes."

ANALYSIS:
The court thus held that the two causes of action were not identical and that there was no evidence to show that implied warranty claim was necessarily subsumed by the strict liability claim. Accordingly, the court concluded that the underlying verdict was theoretically reconcilable under state law.

OUTCOME: The court answered the first certified question in the negative, the second certified question in the negative, and the third certified question in the affirmative.

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