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contractnegligencewillduty of care
contractplaintiffnegligenceappealwillduty of care

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Snyder v. American Ass’n of Blood Banks, 144 N.J. 269, 676 A.2d 1036, 64 USLW 2816

Facts

William Snyder contracted AIDS after receiving a blood transfusion from the Bergen Community Blood Center (BCBC), which was a member of the AABB. At the time of Snyder's transfusion in 1984, there were no direct tests for HIV, but other means of screening were available. The AABB had a significant role in the blood-banking industry and was responsible for setting standards that could have prevented the transmission of HIV through blood transfusions. Snyder filed a complaint against the AABB, alleging negligence for not recommending surrogate testing of blood donors.

Plaintiff William Snyder contracted Acquired Immune Deficiency Syndrome (AIDS) from a transfusion of blood that the Bergen Community Blood Center (BCBC), a non-profit blood bank, had provided to St. Joseph's Hospital.

Issue

Did the AABB owe a duty of care to Snyder, and was it entitled to charitable immunity?

The primary issue is whether the AABB owed a duty of care to Snyder. A further issue is whether the AABB is entitled to charitable immunity under N.J.S.A. 2A:53–7.

Rule

The court determined that the AABB owed a duty of care to blood product recipients and that it was not entitled to charitable immunity under New Jersey law.

The Appellate Division explained that the “unique and dominant role of the AABB in blood-banking and the extent of its control over its institutional members” established the requisite relationship between the AABB and blood-product recipients, “whose safety is its avowed paramount concern.”

Analysis

The court analyzed the AABB's role in the blood-banking industry and its responsibility to ensure the safety of blood products. It found that the AABB had significant control over blood banks and was aware of the risks associated with AIDS transmission through blood. The court concluded that the AABB's failure to recommend surrogate testing constituted negligence, as it was a substantial factor in Snyder contracting HIV.

The jury further found that the AABB's negligence was a substantial factor in causing Snyder to contract HIV. It also found that the AABB was thirty-percent liable for plaintiffs' injuries.

Conclusion

The court affirmed the lower court's judgment, holding that the AABB was negligent and liable for Snyder's injuries.

We granted the AABB's petition for certification, 142 N.J. 517, 665 A. 2d 1110 (1995), and now affirm.

Who won?

William Snyder prevailed in the case because the court found that the AABB had a duty of care and failed to act reasonably in preventing the transmission of HIV through blood transfusions.

The Appellate Division affirmed. Writing for the court, Judge Pressler stated that, on the interlocutory appeal, the court had determined that the AABB owed Snyder a duty of care, and that the law of the case precluded a different determination.

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