## Facts

- Gerardo Zaza, a Maxwell House employee, was injured while working on a trecar-carbon regeneration system used to produce decaffeinated coffee at a Hoboken plant.
- The system included a quench tank holding hot water and carbon; the overall system was designed and controlled by Maxwell House.
- Maxwell House retained Marquess & Nell, Inc. to prepare final engineering design work for part of the system; Brennan Company, Inc. was hired to assemble and integrate the system.
- International Sheet Metal & Plate Manufacturing, Inc. fabricated the quench tank to Maxwell House/Marquess specifications; its role was limited to fabrication, including cutting holes where specified safety devices could be installed.
- The design specifications contemplated multiple safety devices to prevent molten fluid overflow, but Maxwell House ultimately chose not to install certain recommended safety features.
- On January 28, 1990, while Zaza attempted to clear a clog, hot molten water and carbon overflowed from the quench tank, causing serious burns.
- Zaza sued, asserting that the fabricator and engineering firm bore responsibility for unsafe design or integration, including a claimed nondelegable duty to ensure proper system integration.

## Issues

1. Whether a component fabricator that builds to a sophisticated purchaser’s detailed specifications can be held strictly liable for injuries caused by the purchaser’s integration and operation of a complex industrial system.
2. Whether strict liability may be imposed on a fabricator that neither designed nor installed the system’s safety devices and whose component was not defective as fabricated.
3. Whether an engineering firm that recommended safety devices may be liable when the sophisticated purchaser chose to omit or alter those recommendations, and whether that choice breaks causation.

## Decision

- The New Jersey Supreme Court reversed the Appellate Division and reinstated summary judgment for Marquess and International.
- International was not strictly liable because it fabricated a nondefective component to the purchaser’s specifications and did not control system design, safety-device selection, or integration.
- The Court rejected the claim that International had a nondelegable duty to ensure safe integration of the tank into the larger system.
- Marquess was not liable because it recommended safety devices and the purchaser’s informed decision to omit them was a superseding cause of the injury.

## Legal Principles

- A manufacturer or fabricator of a nondefective component part is generally not strictly liable for injuries caused by the assembled product when the fabricator did not control the overall design, integration, or safety features that created the hazard.
- Strict products liability focuses on placing a defective product into the stream of commerce; liability is not extended to make a limited-role contract fabricator a guarantor of downstream system-level design choices by a sophisticated purchaser.
- A sophisticated industrial purchaser’s informed decision to omit or modify recommended safety measures may break causation for claims against an engineering firm that exercised reasonable care by recommending appropriate safety features.
- No general nondelegable duty exists requiring a component fabricator, acting strictly to specifications, to ensure proper integration of its component into a complex system assembled and controlled by others.

## Conclusion

The court held that neither the contract fabricator nor the engineering firm was responsible for injuries stemming from a sophisticated purchaser’s control over system integration and its decision not to implement recommended safety devices, and it reinstated summary judgment for both defendants.


Zaza v. Marquess & Nell, Inc., 144 N.J. 34, 675 A.2d 620 (N.J. 1996)