## Facts

- William Snyder received multiple blood transfusions during open-heart surgery at a New Jersey hospital in August 1984; the blood was supplied by a community blood center.
- Snyder later learned he had contracted AIDS from the transfused blood.
- At the time, there was no direct HIV test, but surrogate testing and enhanced donor screening were available as possible risk-reduction measures.
- The American Association of Blood Banks (AABB) was a nonprofit professional association whose standards strongly influenced member blood banks and hospitals and played a leading role in blood-banking safety practices nationwide.
- The Snyders alleged AABB knew by the early 1980s that AIDS could be transmitted through blood or blood products but failed to recommend surrogate testing or more aggressive donor screening.

## Issues

1. Whether AABB, as an influential private standard-setting association in a heavily self-regulated industry, owed a duty of reasonable care to blood transfusion recipients regarding recommended safety measures.
2. Whether AABB was protected from liability by charitable immunity or by immunity applicable to quasi-governmental/public entities.
3. Whether the evidence supported the jury’s findings on causation and comparative allocation of fault to AABB.

## Decision

- The Supreme Court of New Jersey affirmed the judgment against AABB.
- The court held AABB owed a duty of reasonable care to foreseeable blood recipients because of its central role and special influence over blood-banking standards intended to protect transfusion patients.
- The court rejected AABB’s claim to charitable immunity and rejected any public-entity or quasi-governmental immunity.
- The court left undisturbed the jury’s finding that AABB’s negligence substantially increased Snyder’s risk and constituted a 30% causative factor, sustaining the resulting proportional damages award.

## Legal Principles

- A private standard-setting organization may owe a duty of reasonable care to third parties foreseeably endangered by negligent formulation or promulgation of safety standards, even absent a direct relationship with the injured person.
- Duty can arise where an association occupies a dominant, relied-upon role in an industry’s safety practices and undertakes responsibility for protecting the end users of the regulated product or service.
- Nonprofit status alone does not confer charitable immunity where the organization’s activities function as professional or technical regulation rather than the type of charitable undertaking protected by statute.
- A private association does not receive governmental/public-entity immunity merely because it exerts strong influence in an area affecting public welfare; statutory immunities turn on legal status as a public body, not industry function.
- Causation and comparative responsibility may be found where negligence is shown to have substantially increased the risk of the harm and the fact-finder reasonably allocates fault based on the evidentiary record.

## Conclusion

The court imposed negligence accountability on a private blood-banking standards organization that exercised special influence over industry safety rules, holding it owed transfusion recipients a duty of reasonable care and could not avoid liability through charitable or quasi-governmental immunity.


Snyder v. Am. Ass'n of Blood Banks, 676 A.2d 1036 (N.J. 1996)