Loop v. . Litchfield
42 N.Y. 351 · New York Court of Appeals · 1870
Facts
A manufacturer sold a piece of machinery with known defects to a buyer, Collister, who understood these defects. Collister used the machine for five years. Later, a neighbor began using the machine for his own purposes. While the neighbor was using it, the machine broke apart due to its original defects, killing the neighbor. The deceased was personally aware of the defects, as Collister had pointed them out and discussed them with him.
Procedural history
A jury found negligence in the construction of the wheel, and that the injury resulted therefrom. The case was then appealed, and this court affirmed the order of the General Term, ordering judgment absolute for the defendants.
Issue
Is a manufacturer liable to a third party, a neighbor of the buyer, for injuries resulting from a defect in machinery that was sold with the defects pointed out and understood by the original purchaser, and which was not inherently dangerous?
Holding
The manufacturer is not liable to the representatives of the deceased party, as the facts presented do not constitute a cause of action. The verdict against the defendants cannot be sustained.
Rule
A manufacturer is generally not liable to a third party for injuries caused by a defective product unless the product is inherently or imminently dangerous to human life, and the injury is a natural and almost inevitable consequence of the defect. Products like an iron wheel, even if defective, are not considered inherently dangerous instruments in the same category as poisons or explosives. Therefore, the bursting of such a wheel and resulting injury is not deemed a natural or expected consequence of its manufacture and sale, especially when the defects were known to the original buyer.
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