## Facts

- Connie Daniell owned a 1973 Ford LTD.
- In 1980, Daniell intentionally entered the car’s trunk as part of a suicide attempt, closed the trunk, and became trapped.
- Daniell remained in the trunk for about nine days before being discovered alive, suffering physical and psychological injuries.
- Daniell alleged the trunk was defectively designed because it lacked an internal release mechanism and that Ford failed to warn about the risk of entrapment.
- Daniell sued Ford asserting strict products liability, negligence, and breach of express and implied warranties.
- Ford moved for summary judgment under Federal Rule of Civil Procedure 56(c).

## Issues

1. Whether an automobile manufacturer can be liable in strict liability or negligence for failing to include an internal trunk release when the plaintiff intentionally confined herself in the trunk during a suicide attempt.
2. Whether the manufacturer had a duty to warn about the risk of being trapped in a trunk lacking an internal release mechanism under the circumstances presented.
3. Whether the absence of an internal trunk release rendered the product unreasonably dangerous or breached express or implied warranties of merchantability or fitness for ordinary purposes.

## Decision

- The court granted Ford’s motion for summary judgment on all claims.
- The court held Daniell’s use of the trunk to confine herself during a suicide attempt was not a reasonably foreseeable use or misuse.
- The court concluded the trunk, without an internal release, was not unreasonably dangerous when evaluated against its ordinary purpose of storing and securing goods.
- The court held Ford had no duty to design an internal release or to warn of the asserted danger in these circumstances.
- The court rejected the warranty claims because the vehicle and trunk were fit for their ordinary purposes.

## Legal Principles

- Summary judgment is proper when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.
- Strict products liability requires a showing that the product was in a defective condition unreasonably dangerous for reasonably foreseeable use.
- A manufacturer’s design and warning duties are limited to reasonably foreseeable uses and risks; the manufacturer is not an insurer against injuries from highly extraordinary, self-injurious conduct.
- A duty to warn generally does not extend to dangers that are open and obvious, particularly where the risk arises from an unforeseeable use.
- Implied warranties of merchantability and fitness focus on the product’s ordinary purposes; atypical uses outside those purposes do not establish breach.

## Conclusion

The court entered judgment for Ford because the plaintiff’s intentional confinement in the trunk during a suicide attempt was not a reasonably foreseeable use, the trunk was not unreasonably dangerous for its ordinary storage function, and Ford therefore had no duty to redesign the trunk with an internal release or to provide additional warnings; the automobile also remained merchantable and fit for its ordinary purposes.


Daniell v. Ford Motor Co., 581 F. Supp. 728 (D.N.M. 1984)