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The traditional res ipsa loquitur jury charge should not be used in strict products liability actions.
John Myrlak was injured at work when his chair collapsed. In his products liability action, Myrlak requested a jury charge on res ipsa loquitur regarding his manufacturing defect claim. The request was denied. The jury found the employer, Port Authority Trans-Hudson Corporation (PATH), negligent. The jury also found that Myrlak failed to establish the existence of a manufacturing defect in the chair. PATH and Myrlak cross-appealed and an appellate court reversed both verdicts and remanded for a new trial. It also concluded that the trial court should have instructed the jury on res ipsa loquitur. PATH challenged this decision.
Should the doctrine of res ipsa loquitur be applied in a strict products liability case when liability is based on an alleged manufacturing defect?
The court held that res ipsa loquitur was a negligence doctrine that could not be used in a strict product liability action. On remand, Myrlak was required to show the incident that harmed him was of the kind that ordinarily occurs as the result of a product defect, and that the incident was not solely the result of other cause than the defect existing at the time the chair left PATH’s control. If Myrlak satisfied those requirements, he would be entitled to a jury charge regarding an inference of a product defect. Judgment was reversed.