New York Court of Appeals

Rinehart Kuelling, Appellant v. Roderick Lean Manufacturing Company, Respondent

November 21, 1905183 N.Y. 78

Summary

The New York Court of Appeals reversed the Appellate Division and ordered a new trial, holding that a manufacturer who willfully and fraudulently conceals a defect in a non‑inherently dangerous machine is liable to third‑party users for injuries caused by that defect. The decision also notes that the case does not turn on negligence law. Justice Bartlett's dissent argued that liability should be limited to inherently dangerous articles.