Nancy Denny, Plaintiffs v. Ford Motor Company, Defendant

Summary

The New York Court of Appeals answered three certified questions, holding that strict products liability and breach of implied warranty are not identical, that the strict products liability claim does not subsume the warranty claim, and that a jury may find no defect under strict liability while finding a breach of warranty. The Court explained the differing defect analyses for the two causes of action. Justice Simons dissented, arguing that the warranty claim is encompassed by strict liability and that the jury’s verdicts are irreconcilable.