Facts
- A hotel guest slipped and fell in a hotel-room bathtub and suffered serious injuries.
- The guest sued the hotel owner, the hotel management company, and the bathtub manufacturer.
- The complaint alleged negligence and strict products liability, asserting the bathtub was defectively slippery and lacked anti-skid measures or handrails.
- Defendants in the premises group sought to bar any strict-liability theory at trial.
- The trial court granted the motion, effectively limiting the case against those defendants to negligence.
- The Court of Appeal issued a writ directing the trial court to allow the strict-liability claim to proceed.
- The California Supreme Court granted review to decide whether strict products liability could apply to a residential landlord (as held in Becker) and, if not overruled, whether the theory could extend to hotel proprietors.
Issues
- Whether a residential landlord who is not part of the manufacturing or marketing enterprise of an allegedly defective condition on the premises may be held strictly liable under products liability doctrine.
- Whether strict products liability, if available against landlords, extends to hotel proprietors for injuries to guests caused by alleged defects in hotel premises not created or marketed by the proprietor.
- Whether plaintiffs injured by defects in premises may proceed against landlords or hotel proprietors only under negligence principles requiring reasonable care.
Decision
- The California Supreme Court overruled Becker v. IRM Corp.
- The Court held it was error to apply strict products liability to a residential landlord not within the manufacturing or marketing enterprise of the defective product or condition.
- The Court held it is likewise improper to impose strict products liability on a hotel proprietor for injuries caused by an alleged defect in hotel premises the proprietor did not create or market.
- The Court reversed the Court of Appeal’s writ permitting the strict-liability claim and remanded, leaving negligence as the operative theory against the premises defendants.
Legal Principles
- Strict products liability is generally confined to manufacturers, retailers, and others in the chain of production and distribution of a product.
- A landlord or hotel proprietor who rents premises is not treated as a product seller for purposes of strict products liability when the alleged defect is not one the landlord/proprietor created or marketed.
- Premises owners and operators may still be liable in negligence if they breach a duty to exercise reasonable care to discover and remedy dangerous conditions.
- Injured plaintiffs may pursue strict products liability against the manufacturer, distributor, or retailer of a defective product that caused the injury, even if strict liability is unavailable against the landlord or hotel proprietor.
Conclusion
The California Supreme Court limited strict products liability to participants in the product’s marketing enterprise, overruled prior authority extending the doctrine to landlords, and held that injuries from defects in premises not created or marketed by a landlord or hotel proprietor must be pursued against those defendants under negligence rather than strict liability.