Facts
- William Cronin, a route salesman, drove a bread-delivery step-van on a rural road in San Joaquin County.
- While Cronin attempted to pass a pickup truck, the pickup turned left, collided with the van, and forced it into a ditch.
- The van contained bread racks and loaded trays restrained by an aluminum safety hasp located behind the driver’s seat.
- During the collision, the safety hasp broke, the trays surged forward, struck Cronin in the back, and propelled him through the windshield.
- Cronin sustained serious injuries and alleged the rack/hasp system was defectively designed and/or constructed because it failed under foreseeable collision forces.
- The truck reached Cronin’s employer through a distribution chain in which J.B.E. Olson Corporation acted as sales agent for the assembled vehicle (chassis, body, and racks) supplied through subcontractors and sold to the employer through a dealership.
Issues
- In a strict products liability action, must the plaintiff prove that the defect made the product “unreasonably dangerous,” in addition to proving defect and proximate causation?
- Did the trial court err by refusing to instruct the jury that “unreasonably dangerous” is an element of strict products liability?
- Was there substantial evidence that a defect in the rack/hasp system was a proximate cause of Cronin’s injuries?
Decision
- The California Supreme Court affirmed the judgment for Cronin (and the workers’ compensation carrier) against Olson.
- The court held that California strict products liability does not require proof that a defect rendered the product “unreasonably dangerous.”
- The court found no instructional error in refusing Olson’s requested “unreasonably dangerous” instruction.
- The court concluded the record contained sufficient evidence of defect and causation based on the failure of the safety hasp and resulting tray impact.
Legal Principles
- In California strict products liability, the plaintiff must prove (1) the product was defective and (2) the defect was a proximate cause of the injury.
- The “unreasonably dangerous” limitation associated with Restatement (Second) of Torts § 402A is not an element of California strict products liability.
- Adding an “unreasonably dangerous” requirement improperly reintroduces a reasonableness inquiry associated with negligence and increases the plaintiff’s burden beyond the strict-liability standard.
- Strict products liability serves to place the costs of injuries caused by defective products on those who market them rather than on injured users who cannot protect themselves.
- A participant in the chain of distribution, including an entity acting as a sales agent for an assembled product, may be held strictly liable when the product reaches the user in a defective condition and causes injury.
Conclusion
The court affirmed liability against the seller in the distribution chain and clarified that California strict products liability requires proof of defect and causation only, rejecting any additional requirement that the defect be shown to make the product “unreasonably dangerous.”