In the case of East River Steamship Corp. et al. v. Transamerica Delaval Inc., 1985, the U.S Supreme Court held that a manufacturer in a commercial relationship has no duty under either negligence or strict products-liability theory to prevent a product from injuring itself. The dispute arose when four supertankers installed with turbines manufactured by Transamerica Delaval malfunctioned during their first few years of service, causing damage to only the turbines themselves and not any other property or persons. The owners of these vessels sought damages for repair costs, lost profits due to downtime and reduction in vessel value caused by this defectiveness under both tort law (negligence) and contract law (warranty). However, the court ruled that such claims were purely economic losses which are not recoverable under tort law but rather should be pursued through contract law remedies as it was more appropriate for commercial disputes over product quality.

In the dissenting opinion for East River Steamship Corp. et al. v. Transamerica Delaval Inc., Justice Stevens argued that a manufacturer's liability should not be limited to physical injury or damage to other property, but should also include damages caused by the failure of its product to perform as expected due to defects in design or manufacture. He contended that this would promote better quality control and provide fair compensation for those who suffer economic loss due to defective products, which aligns with principles of tort law and contract law underpinning product liability rules. Furthermore, he disagreed with the majority’s reliance on Seely v White Motor Co., arguing it was wrongly decided because it failed to consider these principles adequately.