## Facts

- Gerald Robinson, a 17-year-old employee of Plastic Jewel Parts Co., operated a plastic injection molding machine manufactured by Reed-Prentice.
- The machine’s molding cycle brought a movable platen against a stationary platen to form a mold, then reopened after curing to permit removal of the molded part.
- When sold in 1965, the machine included a safety gate intended to prevent access to the mold area during operation and complied with applicable safety requirements.
- Plastic Jewel later cut a 6-by-14-inch hole in the gate to permit continuous feeding of a nylon cord, creating an opening large enough for a worker’s hand to reach the mold area.
- On October 15, 1971, Robinson reached through the opening while the machine cycled; his hand was caught between the molds and severely injured.
- Evidence showed Reed-Prentice personnel had observed similar machines being used with holes cut into safety gates and had been asked to design a gate compatible with that mode of operation; Robinson’s expert testified safer, low-cost alternatives were feasible.

## Issues

1. Whether a manufacturer may be held liable in strict products liability or negligence where, after the product leaves the manufacturer’s control, the purchaser substantially alters a safety device and the alteration is the proximate cause of the plaintiff’s injuries.
2. Whether the manufacturer’s knowledge that purchasers might make or were making such alterations can preserve liability despite the substantial, injury-causing modification.

## Decision

- The Court of Appeals of New York reversed the judgment for Robinson against Reed-Prentice.
- The court held Reed-Prentice was not liable under strict products liability or negligence because Plastic Jewel’s post-sale alteration substantially changed the product and was the proximate cause of the injury.
- The court rejected the argument that foreseeability or awareness of the purchaser’s unsafe alteration, by itself, imposed a duty on the manufacturer to design against the consequences of that substantial modification.

## Legal Principles

- A manufacturer’s liability in strict products liability and negligence is assessed based on the product’s condition when it leaves the manufacturer’s possession and control.
- A purchaser’s subsequent modification that substantially alters the product and is the proximate cause of the injury relieves the manufacturer of liability, including where the modification defeats a safety device.
- Foreseeability that a purchaser may modify a product unsafely does not, standing alone, require the manufacturer to bear losses caused by a substantial, injury-producing alteration by another actor.

## Conclusion

Because the employer’s cutting of a large opening in the safety gate defeated the machine’s protective function, substantially altered the product after sale, and directly caused Robinson’s injury, the manufacturer was not liable in either strict products liability or negligence.


Robinson v. Reed-Prentice Div. of Package Mach. Co., 49 N.Y.2d 471 (1980)