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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

Narrative Opinion Summary

In a lawsuit filed by plaintiffs against Reebok International, Ltd. and Mason Companies, Inc., the central issue concerned the alleged defectiveness of 'Reebok Easytone' shoes, which purportedly caused an injury. The plaintiffs asserted claims of negligence, strict products liability due to design and manufacturing defects, and breach of express and implied warranties. The defendants moved for summary judgment to dismiss these claims, but the motion was denied by the Supreme Court of Erie County, prompting an appeal. The appellate court upheld the lower court's decision, emphasizing that conflicting expert opinions presented a triable issue of fact. The plaintiffs' expert testimony suggested potential dangers and alternative safer designs for the shoes, which necessitated a jury's assessment through a risk-utility analysis. Notably, the court found that the defendants' acknowledgment of designing the shoe to be unstable compounded the safety concerns. Furthermore, the court ruled that allegations of false advertising by the Federal Trade Commission did not resolve the issue of the shoes' stability. Accordingly, the court determined that the negligence and breach of warranty claims were interlinked with the strict products liability claim, thereby justifying the denial of the defendants' summary judgment motion.

Legal Issues Addressed

Breach of Warranty Claims

Application: The court linked the breach of express and implied warranties claims closely with the strict products liability claim, supporting the denial of summary judgment.

Reasoning: 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.

Design Defect and Risk-Utility Analysis

Application: The court deemed the plaintiffs' expert opinions on the shoe's dangers and potential safer designs sufficient to warrant a jury's evaluation of the risk-utility analysis.

Reasoning: 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.

Impact of Advertising Claims on Product Liability

Application: The court concluded that allegations of false advertising by the FTC did not negate the issue of the shoe's stability.

Reasoning: The court concluded that the allegations of false advertising by the Federal Trade Commission did not negate the issue of the shoe's stability.

Strict Products Liability

Application: The court evaluated whether the 'Reebok Easytone' shoes were defective and unsafe for their intended use, despite the defendant's claims of safety.

Reasoning: 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.

Summary Judgment in Product Liability Cases

Application: Defendants' motion for summary judgment was denied due to the existence of conflicting expert opinions, which necessitated a jury's evaluation.

Reasoning: The court highlighted that conflicts between the parties' expert opinions could not be resolved at the summary judgment stage.