The New York Court of Appeals in In re New York City Asbestos Litigation refused to impose a duty of care on an employer to an employee’s wife, who cleaned her husband’s work clothes and was exposed to asbestos (see prior post).   This decision provides a great overview of a basic tort concept that is frequently misunderstood: What determines a duty of care?  The Court uses Hamilton v. Beretta USA Gun Corp., a case determining liability of gun manufacturers, to explain the determination of duty in New York.