Reed v. City of Chicago
263 F. Supp. 2d 1123, 2003 WL 881001 (2003)
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Rule of Law:
Under Illinois law, a seller's warranty extends to a non-purchasing end-user if they are the intended and foreseeable beneficiary of the product's safety features and denying them a cause of action would render the warranty ineffective.
Facts:
- On November 12, 2000, J.C. Reed was arrested and placed in a detention cell at the City of Chicago's Fifth District Police Station.
- Police officers knew Reed was mentally unstable and had witnessed him attempting suicide by slitting his wrists.
- The officers removed Reed's clothing and provided him with a paper isolation gown.
- The gown was designed and manufactured by defendants including Cypress Medical Products.
- Reed used the paper gown, which was intended to be a tear-away safety garment, to hang himself in his cell.
- Reed died as a result of the incident after officers allegedly failed to give him proper medical care.
Procedural Posture:
- Plaintiff Ruby Reed, as administrator of J.C. Reed's estate, filed suit in the U.S. District Court for the Northern District of Illinois.
- The complaint named the City of Chicago, several police officers, and the manufacturers of the isolation gown, including Cypress Medical Products, as defendants.
- Count VI of the complaint alleged a breach of warranty claim against the manufacturers.
- Defendant Cypress filed a Rule 12(b)(6) motion to dismiss Count VI, arguing that the plaintiff's claim was barred because the decedent lacked privity of contract.
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Issue:
Does a claim for breach of warranty under Illinois law extend to a jail detainee who is injured by a product, such as a paper isolation gown, that was purchased by the city for the detainee's use, even though the detainee lacks privity of contract with the manufacturer?
Opinions:
Majority - Moran, Senior District Judge.
Yes, a claim for breach of warranty extends to a non-purchasing jail detainee in this situation. The court reasoned that while Illinois law historically required privity for breach of warranty claims, courts have created exceptions, most notably for employees of a purchasing company. The court expanded this reasoning, stating that the beneficiary of any warranty for a safety gown is necessarily the potentially suicidal detainee. The court determined that the detainee's safety was an implicit part of the basis of the bargain between the manufacturer and the buyer (the City). To deny a person like Reed a remedy would render any safety warranty on the gown meaningless, as the corporate buyer cannot be personally injured by its failure.
Analysis:
This decision significantly expands the class of non-purchasers who can bring a breach of warranty claim in Illinois, moving beyond the established exception for employees. It establishes a functional test based on the purpose of the product and the warranty, allowing claims by foreseeable end-users whose safety is the very reason for the product's existence. This signals a move away from strict adherence to the categories listed in UCC § 2-318 towards a more flexible, policy-driven approach to privity, particularly in personal injury cases involving safety equipment.
