## Facts

- A Wisconsin municipality purchased a completed fire truck from a retail seller-assembler.
- The truck’s chassis was manufactured by one company, and the wheels were manufactured by another.
- During normal, intended use, a wheel failed, causing the truck to tip over and sustain substantial damage.
- Evidence supported that the wheel was defective and that the defect was not caused by misuse or post-sale modification by the purchaser.
- The municipality sued the seller-assembler, the chassis manufacturer, and the wheel manufacturer under strict products liability for supplying a defective and unreasonably dangerous product.

## Issues

1. Whether manufacturers of component parts incorporated into a finished product may be held strictly liable for defects in those components that cause harm to the ultimate user.
2. Whether a wheel failure during ordinary operation renders the product “unreasonably dangerous” under strict liability doctrine.
3. Whether the evidence was sufficient to support findings that the defect existed when the component left defendants’ control and that it caused the damages.

## Decision

- The court affirmed judgment for the municipality on strict liability.
- Component-part manufacturers that place parts into the stream of commerce for integration into finished products may be treated as “sellers” subject to strict liability for defects in their components.
- A wheel that fails during normal use, causing loss of control and a rollover, can constitute a defective condition that is unreasonably dangerous.
- The record supported the jury’s findings that the defect existed when the component left the manufacturers’ control and that the defect caused the accident and resulting damage.

## Legal Principles

- Strict products liability applies to entities in the marketing chain engaged in the business of supplying products, including component-part manufacturers whose parts are expected to reach users through integration into a finished product.
- A product is “unreasonably dangerous” when it is dangerous to an extent beyond what an ordinary consumer would contemplate, with ordinary community knowledge about the product’s characteristics.
- A plaintiff must prove that the product was defective when it left the defendant’s control, reached the user without substantial change relevant to the defect, and that the defect was a cause of the harm.
- Policy justifications supporting strict liability include risk allocation to product suppliers, incentives for quality control, and protecting end users who cannot practically inspect for latent defects.

## Conclusion

The court held that strict products liability extends to component-part manufacturers when a defective component integrated into a finished product fails during normal use, renders the product unreasonably dangerous, and causes harm, and it affirmed the jury’s verdict for the purchaser against the seller-assembler and the component manufacturers.


City of Franklin v. Badger Ford Truck Sales, Inc., 207 N.W.2d 866 (Wis. 1973)