Campo v. Scofield

New York Court of Appeals · Torts

TortsProducts liabilityManufacturer negligencemanufacturer liabilityremote userlatent defectconcealed dangerpatent peril

Facts

Plaintiff was working on his son's farm and feeding onions into an onion-topping machine when his hands were caught in the machine's revolving steel rollers and were so badly injured that amputation was necessary. The machine had exposed rollers, and starting or stopping it required shifting a gear on the tractor about fifteen feet from the operator's position. Plaintiff alleged that defendants manufactured and sold the machine, impliedly represented that it was properly designed and safe, and negligently failed to provide guards to prevent contact with the rollers and a stopping device to reduce injury. There was no allegation of privity between plaintiff and the manufacturers.

Issue

Whether a remote user states a negligence claim against a manufacturer by alleging only that a machine with obvious exposed rollers lacked guards and a stopping device, without alleging any latent defect, concealed danger, or danger unknown to the user.

Rule

When a machine is dangerous because of the way it functions and that danger is patent, the manufacturer owes remote users only a duty to make it free from latent defects and concealed dangers. A remote user must allege and prove a latent defect or a danger not known to the user; the manufacturer is under no duty to make the machine accident-proof, foolproof, or more safe against obvious and patent perils.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Salinas, California, Mateo Ruiz borrowed a commercial lettuce slicer from his neighbor's farm. The machine had an exposed rotating blade plainly visible from the operator's station, and Mateo cut his hand while feeding produce into it. He sued the manufacturer, Loma Verde Equipment, alleging the machine was negligently designed because it lacked a shield that could easily have been installed.

Under the majority rule, is Mateo's negligence claim against the manufacturer most likely sufficient?

Explanation. The majority rule permits a remote user to recover in negligence only if the product had a latent defect or concealed danger not known to the user. An exposed cutting blade presents a patent and obvious peril. Alleging merely that a feasible shield could have been added seeks to require the manufacturer to make the machine more safe against an obvious hazard, which the majority rejects.