Sprung v. MTR Ravensburg, Inc

In Sprung v. MTR Ravensburg, Inc., 99 NY2d 468 [2003] the Court of Appeals discussed the public policy theory behind strict products liability and the exception for a casual manufacturer or seller. Essentially, the manufacturer has the ability and the incentive to ensure that the products it manufactures are safe. In turn the seller of such products is in a special relationship to the public that buys and uses such products. If there are costs associated with defective products, such regular manufacturers and sellers are better able to bear such costs as business expenses. However, "Those same public policy considerations are inapplicable where sales of the product are not part of the ordinary course of the seller's business" (Ibid. at 473). In Sprung, the Court of Appeals held that a company whose business was custom manufacturing could not claim "casual manufacturer" status since it held itself to its customers as an expert in the fabrication of custom products. The sale of, in that case, a retractable floor was therefore part of the custom manufacturer's normal course of business.