Castro v. QVC Network Inc.
United States Court of Appeals for the Second Circuit
139 F.3d 114 (1998)
- Written by Sarah Hoffman, JD
Facts
QVC Network, Inc. (QVC) (defendant) advertised a roasting pan on a home-shopping channel that was described as suitable for cooking a number of things, including casseroles, cookies, and a 25-pound turkey. Loyda Castro (plaintiff) bought the pan and cooked a 25-pound turkey in it. While removing the pan from the oven, she lost control of the pan due to the handles’ small size, and it tipped toward her, spilling hot drippings and fat on her foot and ankle. Castro suffered second- and third-degree burns. Castro filed suit on the grounds that the pan was defective. She claimed causes of action for strict liability and breach of warranty. Castro requested separate jury charges for the two claims, but the judge refused. Only the strict-product-liability charge was given to the jury. The jury found that the roasting pan was unsafe for roasting a 25-pound turkey. However, using the risk/liability analysis appropriate to a strict-liability claim, the jury found that the pan was useful for cooking low-volume foods and that that usefulness outweighed the risk of injury from cooking heavier foods. The jury, therefore, found that the roasting pan did not fail the risk/liability test and found in favor of QVC under the strict-liability charge. Castro filed a motion for a new trial, which was denied. Castro appealed.
Rule of Law
Issue
Holding and Reasoning (Calabresi, J.)
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