Halloran v. Va. Chems., Inc.

41 N.Y.2d 386, 393 N.Y.S.2d 341, 361 N.E.2d 991 (1977)

 

RULE:

In a products liability case it is now established that, if plaintiff has proven that the product has not performed as intended and excluded all causes of the accident not attributable to defendant, the fact finder may, even if the particular defect has not been proven, infer that the accident could only have occurred due to some defect in the product or its packaging.

FACTS:

Plaintiff Frank Halloran, an automobile mechanic filed suit for injuries he sustained while using a can of refrigerant packaged and sold by the chemical company. He obtained a verdict in his favor, after a jury trial on the issue of liability only. The chemical company appealed in a personal injury products liability action. A divided Appellate Division affirmed, and certified a question of law for review.

ISSUE:

Should the evidence that Halloran had previously used an immersion heating coil to heat cans of the refrigerant been admissible to show that on the particular occasion, Halloran was negligent and ignored the labeled warnings on the can?

ANSWER:

Yes

CONCLUSION:

The reviewing court determined that evidence that Halloran had previously used an immersion heating coil to heat cans of the refrigerant should have been admissible to show that on the particular occasion, Halloran was negligent and ignored the labeled warnings on the can. The court reasoned that if Halloran or regularly used an immersion coil to heat the water in which the refrigerant was placed to stimulate its flow, evidence of that habit or regular usage should have been admissible to prove he followed such a procedure on the day of the explosion.

Click here to view the full text case and earn your Daily Research Points.