Facts
- Armando Campos worked for a truck-trailer manufacturer assembling truck tires on a Firestone three-piece rim assembly.
- His work process included placing the assembly in a steel safety cage and inflating the tire while it remained in the cage.
- Campos could not read or write English and received oral workplace instructions about using the cage and staying clear during inflation.
- Firestone supplied written warnings and materials, including a posted chart emphasizing cage use and standing clear; the warnings were text-based.
- While inflating a newly assembled tire in the cage, Campos saw a locking element begin to open and believed separation was imminent.
- Campos reached into the cage to disconnect the air hose while the assembly was still pressurized; the rim assembly exploded and severely injured him.
- Campos and his wife sued Firestone in strict products liability, alleging defective design and inadequate warnings, including failure to provide warnings effective for non-English-speaking or non-literate workers.
Issues
- In strict-liability failure-to-warn claims, does a foreseeable user’s awareness of the danger eliminate the manufacturer’s duty to warn, or is it evidence relevant to proximate causation?
- Must the jury assess the user’s knowledge in deciding whether the lack of an adequate warning was a substantial factor in causing the injury, rather than treating knowledge as a complete bar?
Decision
- The Supreme Court of New Jersey reversed the Appellate Division and reinstated the jury verdict for Campos.
- The Court held that a foreseeable user’s knowledge of the danger does not automatically extinguish a manufacturer’s duty to warn in strict liability.
- The user’s knowledge is considered in determining causation—whether the failure to warn was a substantial factor in producing the injury.
- The Appellate Division erred by treating Campos’s actual knowledge as defeating the failure-to-warn claim as a matter of law.
Legal Principles
- A product can be defective in strict liability if it lacks adequate warnings of dangers associated with reasonably foreseeable use.
- A manufacturer’s duty to warn is evaluated in relation to the foreseeable class of users and the context of use, including foreseeable limitations in literacy or language.
- A user’s awareness of a danger is generally relevant to proximate cause: if an adequate warning would not have changed the user’s conduct, the failure to warn may not be a substantial factor.
- Whether an inadequate warning was a substantial factor in causing the harm is ordinarily for the factfinder, with user knowledge treated as evidence on causation rather than as an automatic defense.
Conclusion
The court held that, in strict-liability failure-to-warn cases, a user’s knowledge of the risk does not eliminate the duty to warn; it bears on whether the absence of an adequate warning caused the injury, a question typically reserved for the jury.