## Facts

- Jaime Camacho purchased a new 1978 Honda Hawk motorcycle in March 1978.
- In May 1978, Camacho collided with an automobile in an intersection and suffered serious leg injuries.
- Camacho and his wife sued the manufacturer and distributor for damages, including strict products liability for defective design.
- Plaintiffs alleged the motorcycle was defectively designed because it lacked “crash bars,” tubular steel bars intended to protect a rider’s legs in a collision.
- Plaintiffs claimed crash bars would have mitigated Camacho’s leg injuries.
- Plaintiffs presented expert testimony that effective leg-protection devices were technologically feasible at the time of manufacture and were available as optional equipment from other manufacturers.

## Issues

1. Whether the absence of leg-protection devices on a motorcycle can constitute a design defect making the product defective and unreasonably dangerous under Restatement (Second) of Torts § 402A.
2. Whether a design-defect claim may be resolved as a matter of law based on the obviousness of the danger and ordinary consumer expectations.
3. Whether summary judgment was proper where plaintiffs presented evidence of feasible, injury-reducing alternative safety designs.

## Decision

- The Colorado Supreme Court reversed the judgment affirming summary judgment for Honda and remanded for further proceedings.
- The court held that the lower courts applied an incorrect standard by treating obvious risk and consumer expectations as dispositive.
- The court ruled that the absence of leg-protection devices could not be excluded, as a matter of law, from constituting a design defect.
- The court concluded that the evidence of feasibility and potential injury reduction created fact questions inappropriate for summary judgment.

## Legal Principles

- In design-defect strict liability, the central inquiry is whether the product is unreasonably dangerous, not whether the danger is obvious or within ordinary consumer contemplation.
- Consumer-expectation reasoning, standing alone, is insufficient to defeat a design-defect claim as a matter of law.
- Design-defect claims are assessed using a multi-factor risk-utility framework, including the product’s utility, the likelihood and severity of injury, and the feasibility and cost-effectiveness of safer alternative designs.
- Under crashworthiness principles, vehicle manufacturers may be required to incorporate feasible safety features that reduce the severity of foreseeable accident injuries, even when collisions are an inherent risk of use.
- Whether a product is defective and unreasonably dangerous is generally a jury question when it depends on disputed technical evidence and competing inferences about design choices.

## Conclusion

The Colorado Supreme Court held that a motorcycle’s lack of crash bars could support a strict-liability design-defect claim and that obviousness of risk does not eliminate liability as a matter of law; the case required a fact-specific risk-utility evaluation by the trier of fact.


Camacho v. Honda Motor Co., 741 P.2d 1240 (Colo. 1987)