Campo v. Scofield

301 N.Y. 468, 95 N.E.2d 802 (1950)



If a manufacturer does everything necessary to make the machine function properly for the purpose for which it is designed, if the machine is without any latent defect, and if its functioning creates no danger or peril that is not known to the user, then the manufacturer has satisfied the law's demands. The courts have not yet reached the state where a manufacturer is under the duty of making a machine accident proof or foolproof. Just as the manufacturer is under no obligation, in order to guard against injury resulting from deterioration, to furnish a machine that will not wear out, so he is under no duty to guard against injury from a patent peril or from a source manifestly dangerous.


Appellant worker was operating a farm machine purchased from appellee manufacturer when he caught his hands in the machine causing extreme injury. Appellant brought an action against appellee alleging that appellee had been negligent in failing to equip the machine with a guard or stopping device. The lower court dismissed the complaint.


Is a manufacturer liable for the obvious and known dangers of its products?




The court affirmed the dismissal, holding that because the duty owed by appellee to remote users did not require him to guard against hazards apparent to the casual observer or to protect against injuries resulting from appellant's own patently careless and improvident conduct, the complaint was properly dismissed. The court found that appellee only had a duty to protect against latent dangers in the machine and that the machine was not defective. As such, because the dangers of the machine were obvious, the appellee had no duty to provide warnings against obvious danger - more so that the machine was not inherently defective in the first place.

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