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New York law

Product Liability Laws in New York.

New York applies strict product liability for design, manufacturing, and warning defects under common law (adopted in Codling v. Paglia, 32 N.Y.2d 330 (1973)) with implied warranty under the UCC. New York has no product-liability statute of repose. For design defects, New York applies a risk-utility balancing test (Voss factors). No statutory cap on compensatory damages. Punitive damages available for conduct showing malice, spite, or reckless disregard.

Last verified: 2026-04-17

State law

Statute of Limitations

3 yearsCPLR § 214

3-year personal injury statute applies to product liability. No statute of repose.

State law

Damage Caps

Compensatory Damages: No cap

New York does not cap compensatory damages in product-liability cases.

Punitive Damages: No statutory cap

Punitive damages available for malicious or reckless conduct. Subject to constitutional due-process review.

State law

Key New York Statutes

Strict Product LiabilityCodling v. Paglia, 32 N.Y.2d 330 (1973); Restatement (Second) Torts § 402A

Product sellers are strictly liable for injuries caused by products in defective condition unreasonably dangerous to the user or consumer.

Design Defect — Risk-Utility (Voss Factors)Voss v. Black & Decker Mfg., 59 N.Y.2d 102 (1983)

Seven-factor risk-utility test: product utility; risk likelihood; alternative designs; manufacturer's ability to eliminate risk; user's awareness; user's ability to avoid danger; product cost/safety trade-offs.

Failure to WarnNew York common law

Manufacturers must warn of dangers known or knowable through exercise of reasonable care. Post-sale duty to warn of later-discovered dangers in specified circumstances.

UCC Implied Warranty of MerchantabilityN.Y. UCC § 2-314

Goods must be fit for ordinary purpose. Breach supports recovery of consequential damages including personal injury.

State law

Official Sources

Not Legal Advice

This page summarizes publicly available statutes and rules for informational purposes only. It does not constitute legal advice, and no attorney-client relationship is created by viewing this content. Laws change — always verify with the primary source or consult a licensed attorney in New York.

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