Dorothy Watson v. John O. Marsh, Secretary of the Army

Plaintiff Dorothy Watson, employed by an independent contractor, was injured while working on ammunition at the Lone Star Ammunition Plant in Texarkana, Texas. Her employer operated the plant under a contract with the Department of the Army. The machinery and supplies used were, however, owned by the United States. While operating an assembly machine, her hand became entangled in it, resulting in the amputation of a finger. She sued under the Federal Tort Claims Act, advancing theories of strict liability and negligence.

The district court concluded that a strict liability action could not be…