## Facts

- Yong Lee and her husband owned a small market that included a meat grinder manufactured by Butcher Boy/Lasar.
- The grinder used a standard, off-the-shelf electric motor manufactured by the defendant component supplier.
- On January 15, 1979, Yong Lee’s right hand was pulled into the grinder; her hand and part of her forearm were crushed and amputated.
- Plaintiffs alleged the motor was defectively designed because it did not stop immediately when switched off; they claimed the motor’s “coast-down” increased injury severity.
- The motor was a conventional industrial motor; Lasar specified the motor it wanted and did not seek motor-manufacturer design input for the grinder’s overall safety.
- Evidence indicated even motors with brakes require several seconds to stop after power is cut; instantaneous stopping was not practically achievable.
- The trial court granted summary judgment for the motor manufacturer; plaintiffs appealed.

## Issues

1. Whether a supplier of a standard, noncustom electric motor can be held strictly liable for a design defect based on the motor’s coast-down time when used in a finished meat grinder.
2. Whether a component supplier owes a duty to redesign a standard component, or to anticipate and protect against hazards created by the finished product manufacturer’s configuration and safety choices.

## Decision

- The Court of Appeal affirmed summary judgment for the motor manufacturer.
- The court held the motor, as supplied, was not defectively designed merely because it did not stop instantaneously.
- The motor manufacturer had no duty, on these facts, to redesign a widely used standard motor to meet the particular safety demands of the finished grinder system.
- Plaintiffs failed to raise a triable issue that a feasible safer alternative motor design existed or that the component supplier controlled the design choices creating the hazard.

## Legal Principles

- Under California design-defect doctrine, a product may be defective under either consumer expectations or risk–benefit analysis.
- A standard component-part supplier is generally not strictly liable for injuries caused by the finished product’s design or safety features when the component itself is not defective and the supplier did not control the integration.
- Duty and design-defect responsibility depend substantially on the supplier’s control over the design that created the risk and the reasonableness of requiring the supplier to account for downstream configurations chosen by others.
- Absent evidence of feasible design changes that would materially reduce risk without undue loss of utility or impractical cost, a plaintiff does not create a triable design-defect issue against a component supplier.

## Conclusion

The court affirmed judgment for the electric motor manufacturer because the plaintiffs’ theory targeted hazards tied to the finished meat grinder’s overall configuration and the inherent coast-down of conventional motors, not a defect in the motor as a standalone component or a design choice controlled by the component supplier.


Lee v. Butcher Boy, 215 Cal. Rptr. 195 (Cal. Ct. App. 1985)