Pennsylvania

Cheney v. Village 2 at New Hope, Inc. in Pennsylvania Law

How Cheney v. Village 2 at New Hope, Inc. applies in Pennsylvania: state-specific rules, key cases, and bar exam notes for Torts (Products Liability).

State Approach

Pennsylvania law adheres to the principles of tortious liability, including strict liability in product cases. A plaintiff must establish that a product is defective and that such defect caused injury or damages.

State Rule
Pennsylvania employs the Restatement (Second) of Torts § 402A, applying strict liability for defective products provided that the product reaches the consumer in a defective condition unreasonably dangerous to the user or consumer.
Significant State Cases

Azzarello v. Black Bros. Co.

The court established that the consumer expectation test is the standard for determining product defectiveness in strict liability cases.

Nicolaou v. Martin

In this case, the court ruled that the plaintiff's failure to prove that a defect existed did not support a finding of liability.

Schnatterer v. Pennsylvania Power & Light Co.

The court held that in product liability actions, the burden of proof lies with the plaintiff to show that the product was defective at the time it left the manufacturer's hands.

Comparison to Federal Law

Pennsylvania's strict liability framework closely mirrors the federal standard found in the Restatement (Second) of Torts. However, Pennsylvania courts have been known to apply a more forgiving standard towards establishing defectiveness compared to some federal jurisdictions.

Bar Exam Note

Questions on the Pennsylvania bar exam may include considerations of product liability principles as established in Cheney, testing candidates on comparisons between state and federal approaches.

Practice Pointers
  • Always assess whether the product was in a defective condition at the time of the injury.
  • Evaluate the kind of defect alleged: design defect, manufacturing defect, or failure to warn.
  • Remember the role of expert testimony in establishing the defect and causation.
  • Consider defenses such as misuse or assumption of risk that could negate liability.
  • Stay updated on current case law regarding product liability in Pennsylvania for examination purposes.

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