Facts
- Sandra Lee Elmore bought a new 1962 Rambler American station wagon from Mission Rambler Company, manufactured by American Motors Corporation.
- After routine service at about 1,500 miles, Elmore noticed a “shimmying” at 60–65 mph; the car was not returned for further service before the accident.
- On April 29, 1962, an eyewitness followed Elmore’s car and saw “strong” sparks under it, as if a large metal object suddenly hit the ground.
- Immediately after the sparks, the car began fishtailing, crossed into the wrong lane, and collided with a vehicle driven by Anna May Waters; Elmore was ejected and injured.
- After the collision, inspection showed the front universal joint and drive shaft had detached.
- Plaintiffs presented expert evidence supporting an inference that driveline components were defective when the vehicle left defendants’ control and that such failure could cause loss of control.
Issues
- Whether strict products liability in tort extends to a nonpurchasing bystander injured by a defective product.
- Whether plaintiffs’ evidence of defect and causation was sufficient to submit claims against the manufacturer and dealer to the jury, making nonsuit improper.
- Whether privity limits recovery under implied warranty theories where strict liability principles apply.
Decision
- The Supreme Court of California reversed judgments of nonsuit for both American Motors Corporation and Mission Rambler Company.
- The court held strict products liability applies to foreseeable bystanders as well as users and consumers.
- The court found plaintiffs introduced enough evidence for a jury to infer a defect existed when the vehicle left defendants’ control and that the defect proximately caused the accident.
- The cases were remanded for further proceedings.
Legal Principles
- Strict products liability applies to manufacturers and retailers in the business of distributing products for physical harm caused by defects, when the product is expected to and does reach others without substantial change.
- The doctrine extends to foreseeable bystanders; there is no adequate reason to limit recovery to purchasers, users, or consumers when bystander injury is reasonably foreseeable.
- In ruling on nonsuit, courts must view the evidence and reasonable inferences in the light most favorable to the plaintiff; if a jury could find defect and causation, nonsuit is error.
- Contract-based limits such as privity do not bar recovery where the claim is grounded in strict products liability principles rather than contractual warranty promises.
Conclusion
The court held that strict products liability protects foreseeable bystanders injured by defective products and that plaintiffs’ evidence of a driveline failure causing loss of control was sufficient to require jury determination, requiring reversal of nonsuit and remand for trial.