Daley v. Gemini Bakery Equipment Co.
Court: Appellate Division of the Supreme Court of the State of New York; June 11, 1996; New York; State Appellate Court
Charles Daley, the plaintiff, was injured while operating a dough dividing machine manufactured by Gemini Bakery Equipment Company and used at Denk Baking Corporation. The machine featured a top opening for dough insertion and a large moving blade for cutting, but lacked a safety interlock that would turn off the machine when the hopper door was open. Ten months after Gemini installed the divider, Denk added a hopper, which included a door for manual cleaning of the blade. On January 1, 1989, while attempting to clean the blade, Daley's hand was partially severed when the machine was either still running or inadvertently activated. Gemini sought summary judgment, arguing that the hopper was the cause of the injury and was defective. In response, Daley provided expert testimony stating that the absence of an interlock violated industry standards and contributed to the accident. The IAS Court granted summary judgment to Gemini, concluding that it lacked knowledge of the hopper's design and therefore could not be held liable for not including a safety mechanism. However, the court's reasoning was challenged as flawed. Gemini's assertion that the divider was defect-free assumed a fact that needed to be determined at trial. A product is considered "defective" if it is "not reasonably safe" when it leaves the manufacturer, necessitating a balance between the likelihood and severity of harm against the burden of implementing safety measures. The inherent danger of operating a cutting machine without a safety interlock was evident and not disputed by Gemini, which failed to provide evidence showing that adding such a mechanism was impractical. The court distinguished this case from precedent involving specialized parts of complex machines, asserting that Gemini manufactured the complete machine, including all dangerous elements, and thus bore responsibility for its safety. The lack of a safety interlock was a significant issue that required further examination, as the Supreme Court incorrectly deemed the addition of such a feature impossible. The case highlights a critical question of product safety and liability relating to design defects.