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Mancuso v. Reebok Intl., Ltd.
Citation: 2022 NY Slip Op 04508Docket: 541 CA 21-01206
Court: Appellate Division of the Supreme Court of the State of New York; July 8, 2022; New York; State Appellate Court
Original Court Document: View Document
Sallie and Samuel Mancuso filed a lawsuit against Reebok International, Ltd. and Mason Companies, Inc. after Sallie Mancuso fell while wearing "Reebok Easytone" shoes in her home. The plaintiffs claimed negligence, strict products liability due to design and manufacturing defects, and breach of express and implied warranties. The defendants sought summary judgment to dismiss the complaint, but the Supreme Court of Erie County denied their motion, leading to the appeal. The Appellate Division affirmed the lower court's decision. The court noted that even if the defendants demonstrated that their product was not defective and was safe for intended use, the plaintiffs raised a triable issue of fact regarding a specific flaw in the shoes. Plaintiffs' expert provided opinions about the shoe's dangers and potential safer designs, which the court found sufficient to warrant a jury's evaluation of the risk-utility analysis. The court highlighted that conflicts between the parties' expert opinions could not be resolved at the summary judgment stage. Additionally, Reebok's acknowledgment of intentionally designing the shoe to be unstable contributed to the argument that the shoe was, in fact, unstable. The court concluded that the allegations of false advertising by the Federal Trade Commission did not negate the issue of the shoe's stability. Ultimately, the court determined that the negligence and breach of warranty claims were closely tied to the strict products liability claim, and thus the denial of the defendants' motion for summary judgment was appropriate.