Larsen v. Gen. Motors Corp. - 391 F.2d 495 (8th Cir. 1968)

Rule:

A manufacturer is liable for the negligent construction of an automobile. It is the duty of a manufacturer to use reasonable care under the circumstances to so design his product as to make it not accident or foolproof, but safe for the use for which it is intended. This duty includes a duty to design the product so that it will fairly meet any emergency of use which can reasonably be anticipated. The manufacturer is not an insurer that his product is, from a design viewpoint, incapable of producing injury.

Facts:

Plaintiff-appellant Erling David Larsen received severe bodily injuries while driving, with the consent of the owner, a 1963 Chevrolet Corvair. A head-on collision, with the impact occurring on the left front corner of the car, caused a severe rearward thrust of the steering mechanism into the plaintiff's head. The car was manufactured by appellee General Motors Corporation and liability was asserted against them on an alleged design defect in the steering assembly and the placement or attachment of the component parts of the steering assembly to the structure of the car. The plaintiff did not contend that the design caused the accident but that because of the design, he received injuries he would not have otherwise received or, in the alternative, his injuries would not have been as severe. The rearward displacement of the steering shaft on the left frontal impact was much greater on the car than it would be in other cars that were designed to protect against such a rearward displacement. Plaintiff filed a negligence action alleging that the defendant’s negligent design of a steering assembly caused his injuries in a car accident. Defendant filed a motion for summary judgment and argued that its alleged defect did not cause the accident and that there was no law that imposed a duty of care in the design of an automobile to make it safer to occupy in the event of a collision. The lower court agreed with the defendant and rendered summary judgment in its favor. The court held that there was no common law duty on the manufacturer to make a vehicle that would protect the plaintiff from injury in the event of a head-on collision and dismissed the complaint. Plaintiff timely appealed. 

Issue:

Was the district court correct in holding that appellees did not have a duty to make a car safer to occupy in the event of a collision?

Answer:

No.

Conclusion:

The court reversed the granting of summary judgment and remanded the case. The appellate court held that there did exist a duty of care by the defendant and that the lower court had to determine whether or not the defendant had met this duty. The court found that courts had consistently held that a manufacturer was liable for its negligent construction of an automobile. Further, the court ruled that the defendant had to use reasonable care to design the product for the use for which it was intended. As accidents were not uncommon, a duty did exist.