John Ramos, Respondent v. Howard Industries, Inc., Appellant

Summary

The New York Court of Appeals reversed the Appellate Division and granted summary judgment to Howard Industries, holding that the plaintiff failed to exclude all non‑defendant causes of the transformer explosion and therefore could not survive summary judgment. The Court relied on the Speller standard that a plaintiff must prove the product failed as intended and eliminate alternative causes. Justice Jones dissented, arguing that the defendant had not met its burden because the transformer was unavailable for testing.