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Keywords

liabilitytrialleasestrict liability
liabilitytrialwillleasestrict liability

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Rodgers v. Christie, 795 Fed.Appx. 878 (Mem)

Facts

June Rodgers's son was murdered by a man who had recently been granted pretrial release by a New Jersey state court. In response, she filed a products liability claim against the foundation responsible for the Public Safety Assessment (PSA), a risk assessment tool used in the state's pretrial release system. The District Court dismissed her complaint, concluding that the PSA does not meet the definition of a 'product' under the NJPLA.

June Rodgers's son was tragically murdered, allegedly by a man who days before had been granted pretrial release by a New Jersey state court. She brought products liability claims against the foundation responsible for the Public Safety Assessment (PSA), a multifactor risk estimation model that forms part of the state's pretrial release system.

Issue

Is the Public Safety Assessment (PSA) considered a 'product' under the New Jersey Products Liability Act (NJPLA)?

Is the Public Safety Assessment (PSA) considered a 'product' under the New Jersey Products Liability Act (NJPLA)?

Rule

The NJPLA imposes strict liability on manufacturers or sellers of certain defective 'product[s],' defined as 'tangible personal property distributed commercially for use or consumption' or items whose distribution and use are sufficiently analogous to tangible personal property.

The NJPLA imposes strict liability on manufacturers or sellers of certain defective 'product[s].' N.J. Stat. Ann. § 2A:58C-2.

Analysis

The court determined that the PSA does not fit the definition of a 'product' because it is not commercially distributed and is not tangible personal property. The PSA is described as an 'algorithm' or 'formula' used for risk assessment, which does not fall under the NJPLA's definition of a product. The court also noted that extending strict liability to the distribution of ideas would raise First Amendment concerns.

The PSA does not fit within that definition for two reasons. First, as the District Court concluded, it is not distributed commercially. Rather, it was designed as an 'objective, standardized, and … empirical' 'risk assessment instrument' to be used by pretrial services programs like New Jersey's. N.J. Stat. Ann. § 2A:162-25(c)(1).

Conclusion

The court affirmed the District Court's dismissal of Rodgers's complaint, concluding that the PSA is not a 'product' under the NJPLA.

For the foregoing reasons, we will affirm the District Court's order dismissing the complaint.

Who won?

The prevailing party is the foundation responsible for the Public Safety Assessment (PSA), as the court upheld the dismissal of Rodgers's complaint based on the conclusion that the PSA does not qualify as a product under the NJPLA.

The prevailing party is the foundation responsible for the Public Safety Assessment (PSA), as the court upheld the dismissal of Rodgers's complaint based on the conclusion that the PSA does not qualify as a product under the NJPLA.

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