In New York, product liability law allows an injured person to bring a lawsuit when a product causes harm because it was not reasonably safe. One type of claim involves defective design. In these cases, courts ask whether the product’s design created an unreasonable risk of harm when used as intended. Even when a product functions correctly, it may still be unsafe if a safer design was available at a reasonable cost. This case involved a circular saw and whether it had a design that made it unsafe to use, even though the safety guard worked as intended.
Background Facts
The plaintiff used a circular power saw made by Black & Decker to cut wood for a home project. He stood in his driveway, cutting 2×4 boards on sawhorses. He held the saw in his right hand and braced the wood with his left. The saw had a guard over the blade that retracted when cutting and was supposed to return to a closed position when not in use.
While cutting, the saw hit a knot in the wood. This caused the saw to jump upward about 18 inches into the air. The guard closed in the time it took the saw to rise and fall. But when the saw came down, the exposed portion of the blade struck the plaintiff’s left hand, cutting deeply and severing part of his thumb.
The plaintiff testified that the saw blade guard was functioning normally and had closed to the maximum point allowed by its design. He claimed the guard still left too much of the blade exposed and that this made the saw unsafe. An expert witness supported this view, testifying that it would have been possible to design the guard to cover more of the blade and that the saw did not meet minimum safety standards set by Underwriters Laboratories.
Issue
Whether the plaintiff presented enough evidence to require a jury to decide if the saw was defectively designed and therefore not reasonably safe under New York’s strict products liability law.
Holding
The Court of Appeals ruled that the trial court made a mistake by dismissing the strict products liability claim before sending it to the jury. The court held that the plaintiff had shown enough evidence to support a claim that the saw had a defective design and that the design may have been a substantial factor in causing the injury. The case was sent back to the trial court for a new trial on the strict products liability claim.
Rationale
New York law allows an injured person to bring a product liability claim under several legal theories, including negligence, breach of warranty, and strict products liability. In a strict products liability case involving defective design, the plaintiff must show that the product was not reasonably safe when it left the manufacturer. The design must be such that the danger could have been reduced by a safer design without making the product useless or unreasonably expensive.
In this case, the court focused on whether the plaintiff made a prima facie case, that is, whether the facts presented were enough to allow a jury to reasonably decide in the plaintiff’s favor. The court reviewed the plaintiff’s testimony and expert opinions.
The plaintiff’s expert testified that the guard on the saw left 53 degrees of the blade exposed. The Underwriters Laboratory standard allowed no more than 45 degrees of exposure. The expert also testified that extending the guard to cover more of the blade would have been easy and would have made the saw safer, while still allowing it to function properly.
Although the saw met the manufacturer’s intended function and was not defective in the way it was built or labeled, the court stated that this was not enough to defeat a design defect claim. The issue was whether the saw’s design left the user exposed to an unreasonable risk of harm.
The court explained that a design defect case does not depend on whether the manufacturer acted unreasonably or had knowledge of a problem. Instead, the focus is on whether the product’s design created a risk that outweighed its utility. That is, would a reasonable person conclude that a safer design was available and that the cost and effort of implementing that safer design were worth the reduction in risk?
To help the jury make this decision, the court noted that several factors may be considered:
-
Whether a safer design was available.
-
Whether the safer design would still allow the product to function.
-
The likelihood and seriousness of the injury caused by the product as designed.
-
The cost of implementing a safer design.
-
Whether the user could have avoided injury by using the product more carefully.
-
How much the user knew about the product’s risks.
-
Whether the manufacturer could spread the costs of a safer design.
In this case, the plaintiff had presented enough evidence to raise factual questions on several of these points. His expert’s testimony about blade exposure and industry standards, along with the description of the accident, gave the jury enough information to consider whether the product was not reasonably safe.
The court emphasized that even though the plaintiff lost on his negligence claim, the strict products liability claim should have gone to the jury because it applied a different legal standard. In negligence cases, the plaintiff must show that the manufacturer acted carelessly. In strict products liability cases, the question is whether the product, as designed, posed an unreasonable risk when used as intended.
The court also addressed an issue about other complaints that had been filed against the manufacturer. The plaintiff wanted to use them to show that the manufacturer had notice of a safety problem. The court ruled that this was not relevant to the strict products liability claim, because such claims do not depend on whether the manufacturer knew about the danger. What mattered was the design of the product at the time it was made, not what the company knew later.
Conclusion
The Court of Appeals held that the plaintiff had presented enough evidence for a jury to decide whether the circular saw was defectively designed. The case was sent back to the trial court for a new trial limited to the strict products liability claim. At that trial, both sides would have the chance to present evidence on whether the saw’s design was reasonably safe. The jury would then decide whether the manufacturer should be held responsible for the injuries.
If you or a loved one has suffered serious injuries contact an experienced New York personal injury lawyer at Stephen Bilkis & Associates to discuss your rights and potential claims, and to ensure you receive the justice and compensation you deserve.