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Uniroyal Goodrich Tire Co. v. Martinez - 977 S.W.2d 328 (Tex. 1998)

Rule:

One who sells any product in a defective condition unreasonably dangerous to the user or consumer or to his property is subject to liability for physical harm thereby caused to the ultimate user or consumer, or to his property, if (a) the seller is engaged in the business of selling such a product, and (b) it is expected to and does reach the user or consumer without substantial change in the condition in which it is sold. 

A product is defective in design when the foreseeable risks of harm posed by the product could have been reduced or avoided by the adoption of a reasonable alternative design by the seller or other distributor, or a predecessor in the commercial chain of distribution, and the omission of the alternative design renders the product not reasonably safe. 

Facts:

Roberto Martinez, respondent, suffered personal injuries at work when he was struck by an exploding 16" Goodrich tire that he was mounting on a 16.5" rim. Attached to the tire was a prominent warning label containing yellow and red highlights and a pictograph of a worker being thrown into the air by an exploding tire. Due to these injuries, respondent, together with his wife and children, sued Uniroyal Goodrich Tire Company ("Goodrich"), The Budd Company, and Ford Motor Company. In their suit, the Martinezes did not claim that the warnings were inadequate, but instead alleged that Goodrich, the manufacturer of the tire, Budd, the manufacturer of the rim, and Ford, the designer of the rim, were each negligent and strictly liable for designing and manufacturing a defective tire and rim. Budd and Ford settled with the Martinezes before trial, and the case proceeded solely against Goodrich. At trial, the Martinezes claimed that the tire manufactured by Goodrich was defective because it failed to incorporate a safer alternative bead design that would have kept the tire from exploding. This defect, they asserted, was the producing cause of Martinez's injuries. Further, they alleged that Goodrich's failure to adopt this alternative bead design was negligence that proximately caused Martinez's injury. Martinez’s expert witness testified that the manufacturer knew that the tape beads were prone to break during hang-ups, and that the manufacturer knew a safer alternative product design. The trial court ruled in favor of the respondent, and held that Goodrich was liable for a defective design, thereby awarding them actual and punitive damages. On appeal, however, the appellate court reversed the award of punitive damages, holding that there was no evidence of gross negligence. However, the appellate court affirmed actual damages, holding that there was sufficient evidence of a design defect and that an adequate warning did not conclusively establish that the product was not defective. Thereafter, Goodrich filed an application for a writ of error seeking a review of the appellate court’s decision. Goodrich contended that there was no evidence to support the judgment of the lower court.

Issue:

Can a manufacturer, who knew of a safer alternative product design, be liable for injuries caused by the use of its product?

Answer:

Yes.

Conclusion:

The Supreme Court of Texas has adopted the products liability standard set forth in section 402A of the Restatement (Second) of Torts. Section 402A provides that one who sells any product in a defective condition unreasonably dangerous to the user or consumer or to his property is subject to liability for physical harm thereby caused to the ultimate user or consumer, or to his property if the seller was engaged in the business of selling such a product and if it was expected to and did reach the user or consumer without substantial change in the condition in which it is sold. The court stated that in order to prove a design defect, a claimant must establish, among other things, that the defendant could have provided a safer alternative design. The court held there was sufficient evidence of a design defect, and Goodrich was strictly liable for respondents' damages because it knew of a safer alternative product design.

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