inadequate warning (New Jersey) · Go Syfert
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inadequate warning in New Jersey

33 New Jersey opinions name it 2 courts 1979–2026 8 in the last five years

The cases below were cited by New Jersey courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (22)

CaseFollowedCited
Feldman v. Lederle Laboratoriesgreen
nj · 1984 · cited in 4 New Jersey opinions naming this issue, 1984–1994
2 sentences

1994See id. at 449 , 479 A.2d 374 (stating that “defect may take one of three forms: a manufacturing flaw, a design defect, or an inadequate warning”); Freund v. Cellofilm Properties, Inc., 87 N.J. 229, 236-41 , 432 A.2d 925 (1981) (holding that inadequate warning could constitute design defect); Suter v. San Angelo Foundry & Mach.

1994See id. at 449 , 479 A.2d 374 (stating that “defect may take one of three forms: a manufacturing flaw, a design defect, or an inadequate warning”); Freund v. Cellofilm Properties, Inc., 87 N.J. 229, 236-41 , 432 A.2d 925 (1981) (holding that inadequate warning could constitute design defect); Suter v. San Angelo Foundry & Mach.

34
Strumph v. Schering Corp.green
nj · 1993 · cited in 3 New Jersey opinions naming this issue, 2021–2021
2 sentences

2021Super. 309, 323-28 (App. Div. 1992) (Skillman, J., dissenting) (concluding that "a defendant drug manufacturer may not be held liable for an alleged inadequate warning where the only evidence on the issue of causation is the prescribing doctor's unequivocal testimony that his or her decision to prescribe the drug was not affected by the warning") (emphasis added), rev'd on dissent, 133 N.J. 33, 34 (1993).

2021Super. 309, 323-28 (App. Div. 1992) (Skillman, J., dissenting) (concluding that "a defendant drug manufacturer may not be held liable for an alleged inadequate warning where the only evidence on the issue of causation is the prescribing doctor's unequivocal testimony that his or her decision to prescribe the drug was not affected by the warning") (emphasis added), rev'd on dissent, 133 N.J. 33, 34 (1993).

33
Freund v. Cellofilm Properties, Inc.green
nj · 1981 · cited in 6 New Jersey opinions naming this issue, 1984–2012
2 sentences

1996See also Freund, supra, 87 N.J. at 236-41 , 432 A.2d 925 (holding that an inadequate warning could constitute a design defect).

1996See also Freund, supra, 87 N.J. at 236-41 , 432 A.2d 925 (holding that an inadequate warning could constitute a design defect).

26
Suter v. San Angelo Foundry & MacHine Companygreen
nj · 1979 · cited in 3 New Jersey opinions naming this issue, 1981–1994
2 sentences

1994Co., 81 N.J. 150, 176 , 406 A.2d 140 (1979) (“[A] product may be unsafe because of inadequate instructions.”). “[A]n adequate warning is one that includes the directions, communications, and information essential to make the use of a product safe.” Freund, supra, 87 N.J. at 243 , 432 A.2d 925 .

1984Co., 81 N.J. 150, 176 (1979), that “a product may be unsafe because of inadequate instructions.” Indeed, we held in Freund, supra, 87 N.J. at 236-41 , that an inadequate warning could constitute a design defect.

23
Sterling Drug, Inc., a Corporation v. Irene M. Yarrowgreen
ca8 · 1969 · cited in 3 New Jersey opinions naming this issue, 1979–1981
2 sentences

1979See, e.g., Sterling Drug, Inc. v. Yarrow, 408 F. 2d 978, 992 (8th Cir.1969), a prescription drug case, holding that the gist of the cause of action based on an alleged inadequate warning is the same under both Section 388 and 402A.

1979See, e.g., Sterling Drug, Inc. v. Yarrow, 408 F. 2d 978, 992 (8 Cir.1969), a prescription drug case, holding that the gist of the cause of action based on an alleged inadequate warning is the same under both § 388 and § 402A.

23
State v. Marrerogreen
nj · 1997 · cited in 2 New Jersey opinions naming this issue, 2020–2024
2 sentences

2024See ibid.

2020See, e.g., State v. Marrero, 148 N.J. 469, 496-97 (1997) (finding insufficient instruction as to the use of other-crimes evidence harmless because “the evidence of guilt, 30 independent of the other-crime evidence, was nearly overwhelming,” such that the inadequate instruction “did not tip the scales”).

22
Torsiello v. Whitehall Laboratoriesgreen
njsuperctappdiv · 1979 · cited in 2 New Jersey opinions naming this issue, 1979–1981
2 sentences

1981Torsiello v. Whitehall Laboratories, 165 N.J.Super. 311, 320-321, n.2 (App.Div.1979), certif. den., 81 N.J. 50 (1979).

1981Torsiello v. Whitehall Laboratories, 165 N.J.

22
Myrlak v. Port Auth. of NY and NJgreen
nj · 1999 · cited in 1 New Jersey opinions naming this issue, 2026–2026
1 sentence

2026N.J.S.A. 2A:58C-2. 5 The record makes clear that plaintiff no longer asserts the PLA claim for design defect that she pled in her complaint. 34 When a plaintiff premises a PLA claim on an alleged manufacturing defect, the “deviation ‘from the design specifications, formulae, or performance standards of the manufacturer or from otherwise identical units manufactured to the same manufacturing specifications or formulae’” “occurs when the product comes off the production line in a substandard condition based on the manufacturer’s own standards or identical units that were made in accordance with

11
Navarro v. George Koch & Sons, Inc.green
njsuperctappdiv · 1986 · cited in 1 New Jersey opinions naming this issue, 2026–2026
1 sentence

2026N.J.S.A. 2A:58C-2. 5 The record makes clear that plaintiff no longer asserts the PLA claim for design defect that she pled in her complaint. 34 When a plaintiff premises a PLA claim on an alleged manufacturing defect, the “deviation ‘from the design specifications, formulae, or performance standards of the manufacturer or from otherwise identical units manufactured to the same manufacturing specifications or formulae’” “occurs when the product comes off the production line in a substandard condition based on the manufacturer’s own standards or identical units that were made in accordance with

11
Beshada v. Johns-Manville Products Corp.green
nj · 1982 · cited in 1 New Jersey opinions naming this issue, 2022–2022
1 sentence

2022See id. at 333 .

11
Nuwave Investment Corp. v. Hyman Beck & Co. (073551)green
nj · 2015 · cited in 1 New Jersey opinions naming this issue, 2022–2022
1 sentence

2022See 221 N.J. at 500 (“Because it is unclear whether the entirety of the jury award was influenced by the inadequate instruction . . . , the cleanest and most fair resolution is to vacate the entire award and remand this matter for a new trial on damages.”).

11
Wymbs v. Township of Waynegreen
nj · 2000 · cited in 1 New Jersey opinions naming this issue, 2019–2019
1 sentence

2019Wymbs v. Twp. of Wayne, 163 N.J. 523, 537 (2000).

11
Campos v. Firestone Tire & Rubber Co.red
nj · 1984 · cited in 1 New Jersey opinions naming this issue, 2012–2012
2 sentences

2012Under the common law, “[a] product may be unsafe, and therefore defective, because of a failure to warn or an inadequate warning.” Feldman v. Lederle Labs., 125 N.J. 117, 144 , 592 A.2d 1176 (1991) (citation omitted); see also Campos v. Firestone, 98 N.J. 198, 205 , 485 A.2d 305 (1984) (recognizing that no warning, or an inadequate warning, renders a product defective).

2012Under the common law, “[a] product may be unsafe, and therefore defective, because of a failure to warn or an inadequate warning.” Feldman v. Lederle Labs., 125 N.J. 117, 144 , 592 A.2d 1176 (1991) (citation omitted); see also Campos v. Firestone, 98 N.J. 198, 205 , 485 A.2d 305 (1984) (recognizing that no warning, or an inadequate warning, renders a product defective).

11
Beatrice G. Stanback v. Parke, Davis and Companygreen
ca4 · 1981 · cited in 1 New Jersey opinions naming this issue, 1992–1992
11
Elisabeth Kirsch v. Picker International, Inc.green
ca8 · 1985 · cited in 1 New Jersey opinions naming this issue, 1992–1992
11
prod.liab.rep.(cch)p 11,422 Harry Plummer, Cross-Appellant v. Lederle Laboratories, Division of American Cyanamid Company, Cross-Appelleegreen
ca2 · 1987 · cited in 1 New Jersey opinions naming this issue, 1992–1992
2 sentences

1992This principle was relied upon in Plummer v. Lederle Laboratories, 819 F. 2d 349 (2d Cir.1987), cert. denied, 484 U.S. 898 , 108 S.Ct. 232 , 98 L.Ed. 2d 191 (1987), in which the court rejected plaintiff's argument that he could establish the requisite causal relationship between a drug manufacturer's alleged inadequate warning of the risk of contracting contact polio and the prescribing doctor's failure to convey any information regarding this risk to the patient based solely on the jury's disbelief of the doctor's testimony: According to [plaintiff], [the prescribing doctor's] testimony that

1992See, e.g., Thomas v. Hoffman-LaRoche, Inc., supra, 949 F. 2d 806 ; Stanback v. Parke, Davis & Co., 657 F. 2d 642, 645-46 (4th Cir.1981); see also Plummer v. Lederle Laboratories, supra, 819 F. 2d 349 ; Kirsch v. Picker International, Inc., 753 F. 2d 670, 671-72 (8th Cir.1985); Spychala v. G.D.

11
prod.liab.rep. (Cch) P 13,013 Mary Kathryn Thomas v. Hoffman-Laroche, Inc.green
ca5 · 1992 · cited in 1 New Jersey opinions naming this issue, 1992–1992
1 sentence

1992See, e.g., Thomas v. Hoffman-LaRoche, Inc., supra, 949 F. 2d 806 ; Stanback v. Parke, Davis & Co., 657 F. 2d 642, 645-46 (4th Cir.1981); see also Plummer v. Lederle Laboratories, supra, 819 F. 2d 349 ; Kirsch v. Picker International, Inc., 753 F. 2d 670, 671-72 (8th Cir.1985); Spychala v. G.D.

11
Anderson v. Somberggreen
nj · 1975 · cited in 1 New Jersey opinions naming this issue, 1987–1987
11
Somberg v. Andersongreen
scotus · 1975 · cited in 1 New Jersey opinions naming this issue, 1987–1987
11
Chacon v. Granatagreen
scotus · 1975 · cited in 1 New Jersey opinions naming this issue, 1987–1987
11
Haverhill Manor, Inc. v. Commissioner of Public Welfaregreen
scotus · 1975 · cited in 1 New Jersey opinions naming this issue, 1987–1987
11
NOPCO Chemical Division of Diamond Shamrock Chemical Co. v. Blaw-Knox Co.green
nj · 1971 · cited in 1 New Jersey opinions naming this issue, 1987–1987
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Jersey. Read the followed side critically anyway.

Also cited on this issue (23)

CaseCitedYears
Rainbow v. Albert Elia Building Co. green
nyappdiv · 1975
2 sentences

1981E. g., Sterling Drug, Inc. v. Yarrow, 408 F.2d 978 (8 Cir. 1969); Rainbow v. Albert Elia Building Co., Inc., 49 A.D.2d 250 , 373 N.Y.S.2A 928 (1975).

1981E.g., Sterling Drug, Inc. v. Yarrow, 408 F. 2d 978 (8 Cir.1969); Rainbow v. Albert Elia Building Co., Inc., 49 A.D. 2d 250 , 373 N.Y.S. 2d 928 (1975).

31979–1981
Feldman v. Lederle Laboratories green
nj · 1991
2 sentences

2024When liability is premised on the failure to warn or an inadequate warning, the issue becomes whether the manufacturer knew or could have known of the danger and, if so, whether it "acted in a reasonably prudent manner in marketing the product or in providing the warnings given." Id. at 451-52. [Feldman II, 125 N.J. at 144 .] While manufacturers in compliance with FDA labeling requirements are entitled to a rebuttable presumption that the warning labeling was adequate, A-1501-23 25 N.J.S.A. 2A:58C-4,5 the PLA permits a plaintiff to allege the manufacturer was aware of "after-acquired knowledge

2012Under the common law, “[a] product may be unsafe, and therefore defective, because of a failure to warn or an inadequate warning.” Feldman v. Lederle Labs., 125 N.J. 117, 144 , 592 A.2d 1176 (1991) (citation omitted); see also Campos v. Firestone, 98 N.J. 198, 205 , 485 A.2d 305 (1984) (recognizing that no warning, or an inadequate warning, renders a product defective).

22012–2024
Zaza v. Marquess and Nell, Inc. green
nj · 1996
2 sentences

1996In an inadequate warning case, “the defect is in the failure to warn unsuspecting users that the product can potentially cause injury.” Id. at 57 , 675 A.2d 620 .

1996In an inadequate warning case, “the defect is in the failure to warn unsuspecting users that the product can potentially cause injury.” Id. at 57 , 675 A.2d 620 .

21996–1996
Buckelew v. Grossbard green
nj · 1981
2 sentences

2026Here, plaintiff asserts two PLA claims: a claim that the “product causing the harm” was defective because of a manufacturing defect, id. at -2(a), and a claim that the “product causing the harm” was defective because of an inadequate warning, id. at -2(b), -4. 5 To prevail on either claim, plaintiff must prove that the alleged defect in the product caused her harm.

2026Here, plaintiff asserts two PLA claims: a claim that the “product causing the harm” was defective because of a manufacturing defect, id. at -2(a), and a claim that the “product causing the harm” was defective because of an inadequate warning, id. at -2(b), -4. 5 To prevail on either claim, plaintiff must prove that the alleged defect in the product caused her harm.

12026–2026
Cornett v. Johnson & Johnson green
nj · 2012
1 sentence

2024When liability is premised on the failure to warn or an inadequate warning, the issue becomes whether the manufacturer knew or could have known of the danger and, if so, whether it "acted in a reasonably prudent manner in marketing the product or in providing the warnings given." Id. at 451-52. [Feldman II, 125 N.J. at 144 .] While manufacturers in compliance with FDA labeling requirements are entitled to a rebuttable presumption that the warning labeling was adequate, A-1501-23 25 N.J.S.A. 2A:58C-4,5 the PLA permits a plaintiff to allege the manufacturer was aware of "after-acquired knowledge

12024–2024
Grier v. Cochran Western Corp. green
njsuperctappdiv · 1998
1 sentence

2022In the present case, Union Carbide put an inadequate warning on its asbestos bags, despite its knowledge of the deficiency of that warning. 34 Union Carbide points to Grier, 308 N.J.

12022–2022
Tirrell v. Navistar Intern., Inc. green
njsuperctappdiv · 1991
2 sentences

2007Tirrell, supra, 248 N.J.Super. at 398 , 591 A. 2d 643 .

2007Tirrell, supra, 248 N.J.Super. at 398 , 591 A. 2d 643 .

12007–2007
Strumph v. Schering Corp. green
njsuperctappdiv · 1992
2 sentences

2001In Strumph, the plaintiff alleged that she had been injured following her ingestion *1007 of the defendant's drug and that her injuries were the result of an inadequate warning concerning that drug. 256 N.J.Super. at 310 , 606 A. 2d 1140 .

2001In Strumph, the plaintiff alleged that she had been injured following her ingestion *1007 of the defendant's drug and that her injuries were the result of an inadequate warning concerning that drug. 256 N.J.Super. at 310 , 606 A. 2d 1140 .

12001–2001
Graves v. Church & Dwight Co., Inc. green
njsuperctappdiv · 1993
1 sentence

1996Graves v. Church & Dwight Co., Inc., 267 N.J.

11996–1996
State v. Concepcion green
nj · 1988
2 sentences

1995The judge should "mold the instruction in a manner that explains the law to the jury in the context of the material facts of the case." State v. Concepcion, 111 N.J. 373, 379 , 545 A. 2d 119 (1988).

1995The judge should "mold the instruction in a manner that explains the law to the jury in the context of the material facts of the case." State v. Concepcion, 111 N.J. 373, 379 , 545 A. 2d 119 (1988).

11995–1995
Jurman v. Samuel Braen, Inc. green
nj · 1966
2 sentences

1995Merely asking the jury to say whether plaintiff was bitten while lawfully on defendants' property was an inadequate instruction. *25 The trial judge's instructions should "plainly spell out how the jury should apply the legal principles to the facts as it may find them...." Jurman v. Samuel Braen, Inc., 47 N.J. 586, 591-92 , 222 A. 2d 78 (1966).

1995Merely asking the jury to say whether plaintiff was bitten while lawfully on defendants' property was an inadequate instruction. *25 The trial judge's instructions should "plainly spell out how the jury should apply the legal principles to the facts as it may find them...." Jurman v. Samuel Braen, Inc., 47 N.J. 586, 591-92 , 222 A. 2d 78 (1966).

11995–1995
Fabian v. Minster MacH. Co., Inc. green
njsuperctappdiv · 1992
1 sentence

1995Fabian v. Minster Machine Co., 258 N.J.

11995–1995
State v. Binns green
nj · 1988
11992–1992
Vallillo v. Muskin Corp. green
njsuperctappdiv · 1986
11992–1992
Plummer v. Lederle Laboratories green
scotus · 1987
1 sentence

1992This principle was relied upon in Plummer v. Lederle Laboratories, 819 F. 2d 349 (2d Cir.1987), cert. denied, 484 U.S. 898 , 108 S.Ct. 232 , 98 L.Ed. 2d 191 (1987), in which the court rejected plaintiff's argument that he could establish the requisite causal relationship between a drug manufacturer's alleged inadequate warning of the risk of contracting contact polio and the prescribing doctor's failure to convey any information regarding this risk to the patient based solely on the jury's disbelief of the doctor's testimony: According to [plaintiff], [the prescribing doctor's] testimony that

11992–1992
McMillan v. United States green
scotus · 1987
1 sentence

1992This principle was relied upon in Plummer v. Lederle Laboratories, 819 F. 2d 349 (2d Cir.1987), cert. denied, 484 U.S. 898 , 108 S.Ct. 232 , 98 L.Ed. 2d 191 (1987), in which the court rejected plaintiff's argument that he could establish the requisite causal relationship between a drug manufacturer's alleged inadequate warning of the risk of contracting contact polio and the prescribing doctor's failure to convey any information regarding this risk to the patient based solely on the jury's disbelief of the doctor's testimony: According to [plaintiff], [the prescribing doctor's] testimony that

11992–1992
Rawl v. Able green
sc · 1917
1 sentence

1992This principle was relied upon in Plummer v. Lederle Laboratories, 819 F. 2d 349 (2d Cir.1987), cert. denied, 484 U.S. 898 , 108 S.Ct. 232 , 98 L.Ed. 2d 191 (1987), in which the court rejected plaintiff's argument that he could establish the requisite causal relationship between a drug manufacturer's alleged inadequate warning of the risk of contracting contact polio and the prescribing doctor's failure to convey any information regarding this risk to the patient based solely on the jury's disbelief of the doctor's testimony: According to [plaintiff], [the prescribing doctor's] testimony that

11992–1992
Dewey v. Brown & Williamson Tobacco Corp. green
njsuperctappdiv · 1988
11990–1990
Sterling Drug, Inc., a Corporation v. Maxine F. Cornish green
ca8 · 1967
11989–1989
Toner v. Lederle Laboratories green
idaho · 1987
11987–1987
O'BRIEN v. Muskin Corp. green
nj · 1983
11984–1984
Torsiello v. Whitehall Laboratories green
nj · 1979
11981–1981
Sterling Jackson v. Coast Paint and Lacquer Company, a Corporation, and Reliance Universal Incorporated, a Corporation green
ca9 · 1974
11981–1981

Statutes the citing opinions construe

NJ § N.J. Stat. § 2A:58C-4 (8) NJ § N.J. Stat. § 2A:58C-1 (7) NJ § N.J. Stat. § 2A:58C-2 (6) USC § 21u.s.c.301 (6) NJ § N.J. Stat. § 2A:58C-5 (4) NJ § N.J. Stat. § 2A:15-5.12 (3) NJ § N.J. Stat. § 2A:58C-3 (3) USC § 21u.s.c.360c(a)(1)(a) (3) USC § 21u.s.c.360c(a)(1)(c) (3) USC § 21u.s.c.360c(i)(1) (3) USC § 21u.s.c.360c(i)(1)(a)(ii) (3) USC § 21u.s.c.360c-360k (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 43 (1954–2026) NJ 33 (1979–2026) IL 29 (1981–2026) OH 22 (1991–2024) WA 21 (1972–2025) PA 21 (1938–2025) FL 19 (1974–2026) MS 17 (1993–2017) TX 17 (1971–2021) ME 14 (1983–2018) CT 10 (1992–2021) NY 9 (1925–2024) NM 9 (1965–2023) IN 9 (1977–2015) NV 8 (1985–2017) IA 8 (1968–2017) WI 8 (1986–2024) OR 8 (1996–2024) MD 7 (1974–2018) AZ 7 (1964–2024) LA 6 (1989–2018) MA 6 (1978–2023) MN 6 (1985–2024) OK 6 (1969–2022) DC 6 (1976–2025) UT 5 (1994–2025) SD 4 (2005–2016) MI 4 (1979–2020) VT 4 (1996–2007) KS 4 (1992–2022) MO 4 (1961–2011) CO 4 (1980–2025) TN 3 (2010–2016) GA 2 (1986–2019) ND 2 (1980–1980) MT 2 (2011–2017) SC 2 (2003–2003) KY 2 (2022–2023) HI 2 (1995–2014) NC 2 (1993–2003) ID 2 (2012–2013)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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