## Facts

- Derald Allen Beck died when a Caterpillar model 944 front-end loader rolled down an embankment while he was backing it on a dirt and gravel road with soft shoulders.
- The 944 loader was designed in the late 1950s and first sold in 1964; the unit involved was delivered as a standard machine without a cab and later sold used to Beck’s partnership.
- At the time of the accident, the loader had a bolted-on fiberglass canopy that lacked structural support and was not designed to protect the operator in a rollover.
- It was undisputed that a properly designed roll-over protective structure (ROPS) would have prevented Beck’s fatal injuries.
- Beck’s widow, as personal representative, sued Caterpillar on a strict products-liability design-defect theory alleging the failure to include ROPS made the loader unreasonably dangerous.
- The trial court instructed the jury that if a product fails to incorporate a design feature and injury results, the product is defective; the jury returned a verdict for the plaintiff and awarded damages.

## Issues

1. Whether instructing that a product is defective if it lacks a design feature and injury results improperly converted strict products liability into absolute liability.
2. Whether the trial court erred by failing to define “design defect” and “unreasonably dangerous” with a meaningful legal standard for the jury.
3. Whether it was proper to instruct on the decedent’s comparative negligence in a strict-liability design-defect case.

## Decision

- The Alaska Supreme Court reversed the judgment and remanded for a new trial.
- The court held the design-defect instruction misstated the law by effectively allowing liability based on omission of a safety feature plus resulting injury, without requiring a finding that the product was unreasonably dangerous.
- The court concluded the jury needed a substantive standard to evaluate defectiveness; the instructions did not adequately define “design defect” or “unreasonably dangerous.”
- Because reversal was required on instructional error, the court did not resolve comparative negligence in a manner controlling the outcome, but provided guidance for retrial.

## Legal Principles

- Strict products liability does not make a manufacturer an insurer; liability requires proof the product was defective and unreasonably dangerous.
- A design defect cannot be established solely by showing a safer alternative feature existed and would have prevented the injury; the factfinder must determine whether the design rendered the product unreasonably dangerous under an objective standard.
- Jury instructions in design-defect cases must supply a meaningful legal test (commonly framed through consumer-expectations and/or risk-utility concepts) rather than leaving “defect” to an undefined lay judgment.
- Comparative-fault concepts may bear on strict-liability claims, but they must not displace the central inquiry into the product’s condition and unreasonable danger.

## Conclusion

The court ordered a new trial because the jury instructions collapsed the design-defect inquiry into a missing-safety-feature-and-injury formula, which risked imposing absolute liability and failed to require a finding that the loader’s design was unreasonably dangerous.


Caterpillar Tractor Co. v. Beck, 593 P.2d 871 (Alaska 1979)