Collins v. Promark Products, Inc.
Plaintiff Terry Collins, an employee of the government’s National Park Service, was injured on Ellis Island while using a stump grinder manufactured by defendant Promark Products, Inc. Plaintiff, who had been receiving workers’ compensation benefits, initiated a products liability action against Promark. Promark subsequently impleaded the United States government, alleging negligence in machine maintenance and inadequate instruction. The government moved for summary judgment, contending that New Jersey law should apply under the Federal Tort Claims Act, which would bar the third-party action as workers' compensation would be the sole liability. The court examined an 1833 agreement between New Jersey and New York, consented to by Congress, establishing jurisdictional and territorial limits. The court concluded that New York law applies to the areas on Ellis Island where the tort occurred, granting New York exclusive jurisdiction despite New Jersey's property rights to the underwater land. Consequently, the government’s motion for summary judgment was denied.