Liriano v. Hobart Corp.
Court of Appeals of New York
700 N.E.2d 303 (1998)
Liriano (plaintiff) lost his hand and forearm using a meat grinder manufactured by Hobart Corp. (defendant) after his employer removed the grinder's safety guard; the grinder carried no warning about operating it without that guard. A jury apportioned 95% liability to Liriano's employer, 5% to Hobart, and one-third overall responsibility to Liriano himself, and the Second Circuit certified to the New York high court whether a manufacturer can still be held liable on a failure-to-warn theory in a case where a third party's substantial product modification would otherwise defeat a defective-design claim.
Whether, in a products-liability action, a manufacturer may be held liable under a failure-to-warn theory even where a third party's substantial alteration of the product precludes a defective-design claim.