## Facts

- Shirley Mott, an employee of Clevepak Corp., was injured while working on or near a punch press line that fed steel coil from a motorized stock reel through a roll feed into the press.
- Mott stepped between the stock reel and the roll feed where the steel strip ran close to the floor; the sharp moving stock severed tendons and nerves in her ankle and foot.
- Clevepak ordered a package consisting of a punch press manufactured by Callahan AMS Machine Co., plus a roll feed and stock reel manufactured by Cooper-related entities.
- The roll feed was delivered to Callahan and attached by Callahan to the punch press with bolts; the equipment was then delivered to Clevepak.
- Mott alleged defective design based on the failure to provide guarding between the stock reel and the press line, despite a configuration that permitted workers to walk between the units.
- Cooper argued its roll feed and stock reel were “component” devices usable with other machinery and nonhazardous materials, and that guarding duties belonged to the system seller/assembler or employer.

## Issues

1. Whether component manufacturers can be strictly liable for an alleged design defect when their components are incorporated into a larger integrated machine sold by another manufacturer.
2. Whether responsibility for providing safety guards in a hazardous integrated system may rest with component manufacturers as well as the assembler/seller of the completed package.
3. Whether summary judgment was proper on the ground that component suppliers are not liable as a matter of law for guarding omissions in the integrated system.

## Decision

- The Appellate Division reversed the order granting summary judgment to the Cooper-related defendants and remanded.
- The court rejected a categorical rule insulating component manufacturers from strict liability solely because they supplied only components rather than the complete machine.
- The court held that, given the evidence and the foreseeability of the components’ use in a hazardous configuration, allocation of responsibility for guarding presented factual questions not suitable for summary judgment.

## Legal Principles

- In New Jersey strict products liability, a manufacturer or seller may be liable for harm caused by a defect that makes a product not reasonably safe for its intended or reasonably foreseeable uses.
- A component manufacturer is not automatically exempt from strict liability merely because another entity integrates the component into a larger system.
- If it is reasonably foreseeable that a component will be used in an integrated arrangement creating a continuous hazard, and safety measures may be feasible at the component level, defect and responsibility questions ordinarily go to the factfinder.
- Summary judgment is improper where the record permits reasonable disagreement about defectiveness and about which manufacturer(s) should have incorporated guarding or other safety features.

## Conclusion

The court reinstated the claims against the component manufacturers, holding that foreseeability of hazardous integration and the feasibility of component-level guarding created fact issues on strict liability that could not be resolved by summary judgment.


Mott v. Callahan AMS Mach. Co., 174 N.J. Super. 202, 416 A.2d 57 (App. Div. 1980)