Hoeben v FCA US LLC

Holding The Appellate Division affirmed the denial of summary judgment to the vehicle and component manufacturers, finding that triable issues of fact existed regarding design defects, failure to warn, and implied warranty. The court determined that expert testimony and evidence of alternative designs and internal research created sufficient doubt about the safety and feasibility of the defendants’ products.

The court’s words

a qualified expert opines that a particular product is defective or dangerous, describes why it is dangerous, explains how it can be made safer, and concludes that it is feasible to do so, it is usually for the jury to make the required risk-utility analysis

2026 NY Slip Op 05238, at the official text

the record presents triable issues of fact regarding feasibility of the alternatives

2026 NY Slip Op 05238, at the official text

the evidence does not lead to a definitive conclusion that because Alves would not have heeded the dashboard warning lights anyway, it was immaterial how prominent or conspicuous they were

2026 NY Slip Op 05238, at the official text

the record presents issues of fact concerning whether the design, plans and specifications . . . reveal[ed] any inherent danger in either the component part or the assembled unit

2026 NY Slip Op 05238, at the official text

the vehicle's compliance with federal safety standards constitutes some evidence to be considered, it is not a shield against liability

2026 NY Slip Op 05238, at the official text

the expectations for the performance of the product when used in the customary, usual and reasonably foreseeable manners . . . without regard to the feasibility of alternative designs or the manufacturer's reasonableness in marketing it in that unsafe condition

2026 NY Slip Op 05238, at the official text