Daly v. General Motors Corp.

20 Cal.3d 725

 

RULE:

Strict liability is not absolute liability. Under strict liability, the manufacturer does not become the insurer of the safety of the product's user. The plaintiff's injury must have been caused by a defect in the product. Thus, the manufacturer is not deemed responsible when injury results from an unforeseeable use of its product.

FACTS:

Plaintiffs appealed from a judgment for defendants in the Superior Court in a products liability action. The decedent, who was intoxicated and not wearing his seatbelt or using his door locks, died in a car crash after his door opened on impact and he was thrown from the car. Plaintiffs, the decedent's family, sued defendants, the car manufacturer and distributor, in a products liability action for defective design of the door latch. The jury found for the defendants, and the trial court entered judgment accordingly.

ISSUE:

Whether the trial judge committed prejudicial error when he allowed defendants to introduce evidence without a limiting instruction that the decedent had been drunk and not using safety devices?

ANSWER:

Yes.

CONCLUSION:

On appeal, the court reversed because the trial judge committed prejudicial error when he allowed defendants to introduce evidence without a limiting instruction that the decedent had been drunk and not using safety devices. The court also held that, in future, comparative negligence principles would apply to strict products liability actions. Evidence of compensating design characteristics installed in a motor vehicle by its manufacturer to offset design deficiencies is admissible.

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