Monday, March 25, 2013

Myrlak v. Port Authority of New York and New Jersey case brief

Myrlak v. Port Authority of New York and New Jersey case brief
157 N.J. 84, 723 A.2d 45 (1999)


SYNOPSIS:
On certification to the Superior Court, Appellate Division (New Jersey), defendant manufacturer challenged a judgment that reversed a lower court's decision that a jury should have been charged with a res ipsa loquitur instruction in plaintiff employee's products liability action.

CASE FACTS: Plaintiff employee was injured at work when his chair collapsed. In his products liability action, plaintiff requested a jury charge on res ipsa loquitur regarding his manufacturing defect claim. The request was denied. The jury found the employer negligent. The jury also found that plaintiff failed to establish the existence of a manufacturing defect in the chair. The employer and plaintiff cross-appealed and an appellate court reversed both verdicts and remanded for a new trial. It also concluded that the trial court should have instructed the jury on res ipsa loquitur. Defendant challenged this decision.

HOLDING:
The court held that res ipsa loquitur was a negligence doctrine that could not be used in a strict product liability action.

ANALYSIS:
On remand, the plaintiff was required to show the incident that harmed him was of the kind that ordinarily occurs as the result of a product defect, and that the incident was not solely the result of other cause than the defect existing at the time the chair left defendant's control. If plaintiff satisfied those requirements, he would be entitled to a jury charge regarding an inference of a product defect. Judgment was reversed.

OUTCOME: The appellate court's judgment that the trial court should have given a res ipsa loquitur insturction was reversed because the doctrine of res ipsa loquitur could not be utilized in plaintiff employee's strict product liability action. On remand, the jury could be charged regarding an inference of a product defect only it plaintiff could show his injuries occurred as a result of a product defect.

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