GMC v. Sanchez

997 S.W.2d 584 (Tex. 1999)



A design defect renders a product unreasonably dangerous as designed, taking into consideration the utility of the product and the risk involved in its use. A plaintiff must prove that there is a safer alternative design in order to recover under a design defect theory. An alternative design must substantially reduce the risk of injury and be both economically and technologically feasible. 


Lee Sanchez, Jr. left his home to feed a pen of heifers in March 1993. The ranch foreman found his lifeless body the next morning and immediately called Sanchez's father. Apparently, Sanchez's 1990 Chevy pickup had rolled backward with the driver's side door open pinning Sanchez to the open corral gate in the angle between the open door and the cab of the truck. Sanchez suffered a broken right arm and damaged right knee where the gate crushed him against the door pillar, the vertical metal column to which the door is hinged. He bled to death from a deep laceration in his right upper arm. The family of Sanchez sued the car company, alleging negligence and strict liability in the death of decedent. The trial court jury found that Sanchez was 50 percent responsible for the accident, but the trial court disregarded this finding. The court of appeals held that the Sanchez's responsibility for the accident that resulted in his death should not be compared with the car company's responsibility because Sanchez's actions merely amounted to the failure to discover or guard against a product defect. The court of appeals awarded actual and punitive damages to Sanchez's family. The car company appealed. 


Was the decision of the court of appeals proper?




The court reversed the judgment of the court of appeals and rendered judgment for the family's actual damages, as reduced by the jury's comparative responsibility finding. The court held that comparative responsibility applied in this case because there was evidence that decedent was negligent apart from the mere failure to discover or guard against a product defect. The court further held that punitive damages could not be awarded because the evidence was insufficient to support a finding of gross negligence by the car company.

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