## Facts

- Ryder Truck Rental, Inc. leased a truck to Gagliardi Brothers, Inc. in the regular course of Ryder’s truck rental business.
- A Gagliardi employee drove the leased truck; its braking system allegedly failed, the truck ran a traffic light, and a collision chain injured Dorothy Martin and damaged her vehicle.
- Dorothy Martin and her husband sued Ryder only under strict tort liability (not negligence, warranty, or claims against the lessee/driver).
- The lease required Ryder, at its expense, to provide operating supplies and to maintain and repair the truck, including furnishing labor and parts to keep it in good operating condition.
- The lease required Gagliardi to return the truck to Ryder for service and maintenance at least eight hours weekly and prohibited repairs by anyone not authorized by Ryder.

## Issues

1. Whether a commercial bailment-lease of a motor vehicle, made in the regular course of a truck rental business, may subject the lessor to strict tort liability for injuries to an injured bystander caused by an alleged defect in the leased vehicle.

## Decision

- The Delaware Supreme Court reversed the Superior Court’s grant of summary judgment for Ryder.
- The court held that strict tort liability applies to a bailment-lease of a motor vehicle entered into in the regular course of a truck rental business, in favor of an injured bystander.
- The case was remanded for further proceedings because strict liability was available as a matter of law if plaintiffs proved defect and causation.

## Legal Principles

- Strict products liability in tort may apply to commercial lessors (bailors for hire) who place products into the stream of commerce in the ordinary course of business.
- A commercial lease is not categorically exempt from strict liability merely because the transaction is a bailment rather than a sale.
- Lease terms assigning the lessor continuing responsibility for maintenance and repair support treating the lessor as a commercial supplier for strict-liability purposes.
- Summary judgment is improper where it rests on a legal rule that strict tort liability cannot apply to the bailment-lease relationship as a matter of law.

## Conclusion

Delaware recognized strict products liability in tort as a viable theory against a commercial truck lessor and held that an injured bystander may pursue strict liability for injuries allegedly caused by a defective condition in a leased vehicle, requiring reversal of summary judgment and remand.


Martin v. Ryder Truck Rental, Inc., 353 A.2d 581 (Del. 1976)