Janof v Auto Warehouse

Holding The court reversed the judgment and ordered a new trial because the verdict sheet was internally inconsistent, as it allowed the jury to find the airbag design was not reasonably safe but that the manufacturer was not negligent in selecting that same design. The court determined that separate interrogatories for strict products liability and negligent design were redundant given the substantial factual overlap between the claims.

The court’s words

the separate interrogatories unnecessarily divided what was in essence a single design inquiry and permitted the jury to reach divergent findings without a discernible factual basis for doing so

2026 NY Slip Op 06189, at the official text

the evidence here supplied no factual basis for such a distinction

2026 NY Slip Op 06189, at the official text

the jury simultaneously determined that the design was not reasonably safe or reasonably fit for its ordinary purpose, yet that BMW was not negligent in choosing that design

2026 NY Slip Op 06189, at the official text