Law School Case Brief
Langford v. Chrysler Motors Corp. - 513 F.2d 1121 (2d Cir. 1975)
Under a doctrine of strict products liability, the manufacturer of a defective product is liable to any person injured or damaged if the defect was a substantial factor in bringing about his injury or damages; provided: (1) that at the time of the occurrence the product is being used, whether by the person injured or damaged or by a third person, for the purpose and in the manner normally intended, (2) that if the person injured or damaged is himself the user of the product he would not by the exercise of reasonable care have both discovered the defect and perceived its danger, and (3) that by the exercise of reasonable care the person injured or damaged would not otherwise have averted his injury or damages.
Plaintiff-appellee Francis J. Langford filed a complaint in the United States District Court for the Eastern District of New York for a product liability action alleging that injuries sustained by his minor son in an automobile accident resulted from the negligent manufacture of the automobile by defendant-appellant Chrysler Motors Corp. (Chrysler) and from the negligent servicing of the automobile by the vendor, defendant-appellant Woodbridge Dodge, Inc. Langford alleged that the defendants' breaches of their respective warranties, express and implied, provided the basis of liability. In its answer, Chrysler asserted a counterclaim against Langford for indemnity or contribution, alleging that his negligent operation of the car caused the accident. Chrysler also asserted a cross-claim against Woodbridge Dodge for indemnity or contribution alleging that its negligent servicing of the Langford car and its breach of its warranties caused the accident. The District Court ruled in favor of Langford based on findings that, under New York law of strict product liability, defendant manufacturer was liable for having caused injuries to plaintiff's son, and that defendant dealer, as vendor of the car, was minimally at fault, and entitled to indemnification against defendant manufacturer. Chrysler appealed.
In a strict products liability action, did the trial court properly rule in favor of plaintiff, who alleged his son's injuries from an automobile accident resulted from negligent manufacture of a defective part and negligent servicing?
The district court's judgment in favor of plaintiff-appellee Langford was affirmed by the United States Court of Appeals for the Second Circuit. The Court found that Langford had satisfied the requirements to support a finding of strict liability through plaintiff's testimony about the circumstances of the accident and expert testimony about the defective part. In light of the defendant evidence that indirectly indicated that a tie rod assembly located well within the chassis of the vehicle was not easily alterable, the inference that the car had not been altered between the time of the accident and the trial was proper. Thus, the admission of plaintiff's expert's testimony was within the sound discretion of the trial court. The Court found no evidence to indicate that defendant dealer was negligent when it inspected the car before the accident, which justified the full indemnification award.
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