Halloran v. Virginia Chemicals, Inc.
Court of Appeals of New York
361 N.E.2d 991 (N.Y. 1977)
Halloran (plaintiff), an experienced auto mechanic who had serviced hundreds of air conditioning units using thousands of cans of refrigerant made by Virginia Chemicals (defendant), was injured when a can exploded after he warmed it in a coffee can of hot water using an immersion coil — a method the product's warning label specifically cautioned against. In his ensuing products liability suit, Virginia Chemicals sought to introduce evidence that Halloran habitually used this exact immersion-coil method whenever he needed to speed up refrigerant flow. The trial court excluded this habit evidence, and the appellate court affirmed.
Whether evidence that a products liability plaintiff habitually and repeatedly used a method the manufacturer warned against is admissible to show he acted in conformity with that habit on the occasion causing his injury.