Facts
- William B. Greenman received a Shopsmith combination power tool as a gift after seeing it demonstrated and reviewing a manufacturer-prepared brochure.
- He later purchased attachments to use the Shopsmith as a lathe to turn a large piece of wood.
- While using the lathe function, the wood suddenly flew out and struck Greenman, causing serious head injuries.
- Expert testimony attributed the accident to defective design and construction, including inadequate set screws that allowed vibration to move the tailstock and permit the wood to eject.
- Greenman sued the manufacturer (Yuba Power Products, Inc.) and the retailer for negligence and breach of express and implied warranties.
Issues
- Whether a manufacturer is strictly liable in tort when it markets a product to be used without inspection for defects and a defect causes personal injury.
- Whether a consumer’s claim based on product representations is barred for failure to provide timely notice of breach of warranty under California Civil Code § 1769 in a personal-injury action against a remote manufacturer.
Decision
- The court affirmed the judgment for Greenman against the manufacturer.
- The court held the manufacturer strictly liable in tort for personal injuries caused by a defect in a product it placed on the market for use without inspection.
- The court held the statutory notice-of-breach requirement was not an appropriate bar in an injured consumer’s personal-injury action against a manufacturer with whom the consumer did not deal.
- Because the judgment against the manufacturer was affirmed, Greenman’s conditional appeal from the judgment in favor of the retailer did not affect the retailer’s judgment.
Legal Principles
- A manufacturer is strictly liable in tort when it places a product on the market, knowing it will be used without inspection for defects, and the product has a defect that causes personal injury.
- Strict products liability focuses on defective products and causation, not on contract-based warranty doctrines such as privity or commercial notice rules.
- In personal-injury suits by consumers against remote manufacturers, applying a statutory notice-of-breach requirement designed for buyer-seller disputes is improper; lack of such notice does not defeat recovery under strict liability in tort.
- The policy basis is loss allocation: manufacturers should bear and distribute the costs of injuries from defective products rather than leaving those losses on injured consumers unable to protect themselves.
Conclusion
The court affirmed a verdict for an injured consumer and established that a manufacturer is strictly liable in tort for personal injuries caused by defects in products it markets for use without inspection, while rejecting warranty notice rules as a barrier to such recovery against remote manufacturers.