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Snyder v. Mekhjian

Superior Court of New Jersey, Appellate Division · 1990 · Civil Procedure

Civil ProcedureStrict LiabilityDiscoveryNegligenceBlood Transfusionsstrict liabilityunavoidably unsafe productscomment k

Facts

William Snyder underwent elective heart surgery at St. Joseph's Hospital in August 1984 and, during a second procedure to repair a bleeding artery, received a unit of platelets supplied by Bergen Community Blood Center, a non-profit blood bank. In 1986 the blood center informed the hospital that the donor of that unit later tested positive for HIV antibodies, and Snyder was thereafter found HIV-positive with no other risk factors noted by his physician. Plaintiffs sued the physicians, hospital, blood center, and the American Association of Blood Banks, alleging among other things that available screening and testing methods in 1984 could have reduced the risk of AIDS-contaminated blood. The trial court dismissed the strict-liability claims and denied discovery of donor information, prompting this interlocutory appeal.

Issue

Whether strict liability may be imposed on a non-profit blood bank and others involved in the collection and distribution of transfused blood when, in August 1984, available screening methods could reduce but not eliminate the risk of AIDS contamination. Also, whether plaintiffs are entitled to discovery of otherwise confidential donor information needed to prove causation and negligence, subject to protective limits.

Rule

Strict liability is unavailable when the product at issue is unavoidably unsafe and its safety is beyond the provider's power to ensure, particularly where the provider is a non-profit institution supplying a product vital to public health; in that setting liability rests, if at all, on negligence rather than defective-product principles. AIDS-related donor records protected by statute may be disclosed only by court order for good cause shown, after weighing the public interest and need for disclosure against the injury to the subject, the physician-patient relationship, and the relevant health services, and only with disclosure no broader than necessary and with appropriate safeguards.

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

In 1984, a patient in Newark received plasma supplied by Garden State Community Blood Services, a nonprofit blood bank. Experts agree that if the bank had used every screening interview and surrogate lab method then available, a substantial percentage of infected donations still would not have been detected.

If the patient sues the blood bank on a strict-liability theory for supplying a defective product, what is the best result?

Explanation. The majority held strict liability is unavailable where, at the relevant time, donated blood was unavoidably unsafe because even the best available screening and testing could not eliminate a significant portion of contaminated blood. In that setting, especially with a nonprofit blood provider and a product vital to public health, liability rests in negligence rather than strict liability.