Sunday, November 10, 2013

Liriano v. Hobart Corp. case brief

Liriano v. Hobart Corp. case brief summary
700 N.E.2d 303 (1998)


CASE SYNOPSIS
Defendants, manufacturer and supermarket, sought review of a decision entered by the United States District Court for the Southern District of New York which allowed plaintiff injured to recover damages suffered from defendant manufacturer's failure to warn that the removal of its product's safety feature was dangerous. The United States Court of Appeals for the Second Circuit remanded the matter for determination by the state court.

CASE FACTS

  • Plaintiff injured was a meat cutter working for defendant supermarket. 
  • Plaintiff's arm was amputated by a meat grinder produced by defendant manufacturer. 
  • Defendant supermarket had removed a safety guard placed on the product by defendant manufacturer. 
  • There were no warnings on the meat grinder to indicate that it was dangerous to operate it without the safety feature. 
  • The federal district court dismissed all of plaintiff's claims except that for failure to warn. 
  • The district court entered a jury verdict in favor of plaintiff. 
  • Defendants argued that defendant manufacturer did not have a duty to warn plaintiff. 
DISCUSSION

  • On remand to this state court, it was held that manufacturer liability for failure to warn may exist even in cases where the substantial modification defense would preclude liability on a design defect theory. 
  • However, where reasonable minds may disagree as to the extent of plaintiff's knowledge of the hazard, the question was one for the jury. 
  • The question of whether defendant manufacturer's liability was barred as a matter of law on the facts of this case, viewed in the light most favorable to plaintiff, was to be determined by the federal court of appeals.

CONCLUSION

The decision entering judgment for plaintiff injured was affirmed in part and remanded in part. Although defendant manufacturer's liability for failure to warn may have existed even where the substantial modification defense precluded liability on a design defect theory, whether defendant manufacturer's liability was barred as a matter of law on the facts of the case was to be determined by the federal appeals court.

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