## Facts

- Edward Dosier sued Wilcox-Crittendon Company and North & Judd Manufacturing Company for personal injuries under strict products liability.
- North & Judd manufactured a cast malleable iron snap hook (“No. 333 snap”) primarily intended for animal-handling uses such as bull ties, stallion chains, or cattle ties.
- A United Air Lines buyer purchased the hook in 1964 from a harness and saddlery supplier by selecting it from a display; there was no discussion of intended use at purchase.
- United Air Lines incorporated the hook into a workstand safety rope system at the San Francisco Airport.
- Dosier was injured when the hook allegedly failed during this safety-rope use, causing a fall.
- Dosier alleged (1) a design/manufacturing defect and (2) failure to warn of limitations, including load capacity and unsuitability for human support.
- After trial, judgment was entered for defendants; Dosier appealed.

## Issues

1. Whether a snap hook designed and marketed for livestock restraint was “defective” under strict products liability when repurposed as part of a human fall-protection system.
2. Whether defendants were strictly liable for failure to warn about limitations (including load capacity and unsuitability for human support) when the product was marketed for animal-tie use.
3. Whether the purchaser’s safety use was reasonably foreseeable such that strict liability required design protection against, or warnings about, that use.

## Decision

- The Court of Appeal affirmed the judgment for defendants.
- The court found insufficient proof that the hook was defective when used for its intended animal-tie purposes.
- The court rejected strict liability for failure to warn because the human-support safety use was a materially different application not shown to be reasonably foreseeable from the product’s nature, marketing, and distribution.

## Legal Principles

- Strict products liability requires a defect that makes the product unsafe in light of its intended and reasonably foreseeable uses.
- A product is not defective merely because it fails when adapted to an abnormal or unforeseeable use outside the role for which it was designed and marketed.
- A duty to warn in strict liability extends to risks arising from foreseeable uses of the product; it does not require warnings against remote, atypical repurposings that effectively transform the product into a different kind of safety device.
- Where evidence does not establish that the product was structurally inadequate or unreasonably dangerous for its marketed purpose, an adverse strict-liability verdict will be upheld.

## Conclusion

The court held that strict products liability did not apply because the snap hook was not shown defective for its intended livestock use and defendants had no strict-liability duty to warn against using livestock hardware as human fall-protection equipment absent proof that such a safety use was reasonably foreseeable.


Dosier v. Wilcox-Crittendon Co., 45 Cal. App. 3d 74, 119 Cal. Rptr. 135 (Ct. App. 1975)