Wednesday, December 18, 2013

Halloran v. Virginia Chemicals, Inc. case brief

Halloran v. Virginia Chemicals, Inc. case brief summary
361 N.E.2d 991 (N.Y. 1977)


CASE SYNOPSIS
Defendant chemical company appealed from an order of the Appellate Division of the Supreme Court in the Second Judicial Department (New York), which affirmed an interlocutory judgment upon a verdict in favor of plaintiff automobile mechanic in a personal injury products liability action.

CASE FACTS
Defendant chemical company appealed in a personal injury products liability action from a judgment in favor of plaintiff automobile mechanic, after a jury trial on the issue of liability only, for injuries plaintiff automobile mechanic sustained while using a can of refrigerant packaged and sold by defendant chemical company. The appellate division affirmed and certified a question of law for review.

DISCUSSION

  • The reviewing court determined that evidence that plaintiff automobile mechanic had previously used an immersion heating coil to heat cans of the refrigerant should have been admissible to show that on the particular occasion, plaintiff automobile mechanic was negligent and ignored the labeled warnings on the can. 
  • The court reasoned that if plaintiff automobile mechanic habitually or regularly used an immersion coil to heat the water in which the refrigerant was placed to stimulate its flow, evidence of that habit or regular usage should have been admissible to prove he followed such a procedure on the day of the explosion.
CONCLUSION
The case was remitted to the trial court for a new trial on liability because defendant chemical company should have been able to introduce evidence of plaintiff auto mechanic's habit of using a heating coil to heat cans of refrigerant to establish plaintiff's negligence.

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