New York

Barker v. Lull Engineering Co. in New York Law

How Barker v. Lull Engineering Co. applies in New York: state-specific rules, key cases, and bar exam notes for Torts - Products Liability.

State Approach

New York recognizes both strict liability and negligence claims in products liability cases. The principles from Barker v. Lull Engineering Co. emphasize the focus on product defectiveness and the reasonable expectations of consumers in assessing liability.

State Rule
In New York, the standard for product liability requires showing that a product was defectively designed or manufactured and that such defect caused the plaintiff's injury, aligning with the principles set forth in Barker.
Significant State Cases

Robinson v. Reed-Prentice Division of Package Machinery Corp.

Established that a manufacturer's liability can arise from defects that render a product unsafe for ordinary use.

Bennett v. HMI, LLC

Clarified the requirement for showing a defect in design versus defect in manufacturing in products liability cases.

Voss v. Black & Decker Mfg. Co.

Affirmed that consumer expectations play a key role in determining whether a product is defectively designed.

Comparison to Federal Law

While federal law also acknowledges strict product liability, New York incorporates the consumer expectation standard to evaluate product defects more directly. Additionally, federal standards may focus more on direct evidence of manufacturer negligence rather than the broader consumer expectations recognized in New York.

Bar Exam Note

Questions regarding products liability, particularly in relation to design and manufacturing defects, are common on the New York bar exam, reflecting principles from Barker v. Lull Engineering Co.

Practice Pointers
  • Understand the distinction between manufacturing defect, design defect, and failure to warn.
  • Focus on the consumer's reasonable expectations when analyzing product safety.
  • Keep abreast of case law that interprets and applies the principles from Barker in varying factual scenarios.

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