## Facts

- Antonio Campo worked on his son’s farm feeding onions into an onion-topping machine manufactured by the defendants.
- The machine used exposed, revolving steel rollers that topped onions by grinding.
- The machine could be started or stopped only by shifting a tractor gear located about fifteen feet from the operator’s position.
- While dumping a crate of onions into the machine, Campo’s hands were caught in the rollers, resulting in severe injuries requiring amputation.
- Campo alleged the manufacturer negligently failed to provide (1) guards to prevent contact with the rollers and (2) a stopping device near the operator to reduce injury severity.
- Campo was not in privity with the manufacturer; the machine had been sold to a third party.
- The complaint did not allege a hidden defect or that the danger was unknown; the hazard was the exposed rollers.

## Issues

1. Whether a manufacturer owes a negligence duty to a remote user to install guards or stopping devices when the product’s danger is open and obvious rather than latent or concealed.
2. Whether a complaint states a negligence claim where the only alleged defect is failure to protect against a patent peril inherent in the product’s visible operation.

## Decision

- The New York Court of Appeals affirmed dismissal for failure to state a cause of action.
- The court held that a manufacturer’s duty to remote users is to avoid latent defects and concealed dangers, not to protect against patent, obvious hazards inherent in the product’s operation.
- Because the complaint alleged no hidden defect or concealed danger, the manufacturer had no duty to add guards or nearby stopping mechanisms to protect against the apparent risk.

## Legal Principles

- A manufacturer may be liable in negligence to nonpurchasers, but liability is limited where the alleged hazard is a latent defect or concealed danger.
- No negligence duty arises to redesign or guard a product against a patent peril that is apparent to and can be appreciated by the user.
- Products liability in negligence does not require making a machine accident-proof or foolproof; expanding such safety obligations is a policy choice for the legislature.

## Conclusion

The court held that a manufacturer is not liable in negligence to a remote user for injuries caused by an obvious danger inherent in a machine’s exposed operating parts, absent allegations of a latent defect or concealed hazard.


Campo v. Scofield, 301 N.Y. 468, 95 N.E.2d 802 (N.Y. 1950)