Discussion:
Aroma Housewares Co. is a California corporation that distributes electric kitchen appliances. Aroma distributed between 30,000 and 40,000 juice extractors in the United States. The juicers employed a rapidly spinning metal grater, whose sharp teeth pulverized fruits and vegetables that were inserted through a plastic chute. Aroma began receiving consumer reports of failed juicers. Exploding juicers, the reports claimed, "[threw] with great violence pieces of the clear plastic cover and shreds of the razor-sharp separator screen as far as eight feet." One consumer called the juicer "an unsafe and dangerous machine which exploded in [his] face." A flying blade sliced the hand of another. And one injured woman was taken by ambulance to the hospital, where she stayed overnight, and she sustained permanent damage to her fingers, hand, and arm. In all, Aroma received complaints from 23 consumers. Aroma tested the juicers but was unable to replicate the malfunctions. It reported none of this to the Consumer Product Safety Commission. But some of the consumers did. Alerted to the problems, the commission asked the company to report what it knew about the dangers posed by its juicers. Aroma disclosed the consumer complaints as well as the results of its own tests. A few months later, Aroma and the commission jointly announced that the juicers were being recalled. The United States subsequently sued Aroma, alleging that the company had violated the reporting requirements of the Consumer Product Safety Act. The district court granted partial summary judgment for the United States. Aroma appealed. Did Aroma violate CPSA? Should Aroma have reported the defective juicers even though it could not replicate the malfunctions?