Kaneko v. Hilo Coast Processing

65 Haw. 447, 654 P.2d 343 (1982)



Manufacturers, although strictly liable for injuries from defective products, are not insurers of the safety of the products user. Strict products liability was never intended to be "absolute liability."


Plaintiff ironworker was injured while erecting a mill building for defendant company.  The ironworker fell from a girt that gave way because the connecting clip to the column in the prefabricated mill building had been only tack welded. The prefabricated mill was manufactured by defendant manufacturer but was assembled by a third party. The trial court, entered judgment for the ironworker and against the manufacturer, but reduced the jury award proportionate to the ironworker's percentage of liability.


Is the manufacturer of a prefabricated mill building liable for a defective component part?




The court found that a prefabricated building that must be assembled was a product where the seller-manufacturer may be found strictly liable for injuries caused by a defective component part. This conclusion reaffirmed the public policy of providing maximum protection to injured persons from defects in products. The principal issue raised in the ironworker's cross-appeal was whether the doctrine of comparative negligence should merge with strict products liability. The court rejected the academic argument that the merger of the two concepts was prevented because of semantics. Comparative negligence would only reduce the award by the degree to which a plaintiff is contributorily negligent, and not the liability of a manufacturer of a defective product.

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