## Facts

- Plaintiffs, partners operating a milk distribution business, bought a used reconditioned tractor from White Motor Company.
- The tractor included an air-brake system manufactured by Bendix-Westinghouse and installed by White.
- The brake system allegedly failed, causing a collision with a Chicago Transit Authority bus.
- The collision led to damage to plaintiffs’ tractor-trailer and the bus, and injuries to bus passengers.
- Plaintiffs paid for repairs to their vehicle, repairs to the bus, and settlements of passenger injury claims, including related legal and investigative costs.
- Plaintiffs sued White and Bendix seeking recovery of these expenditures.

## Issues

1. Whether a component-part manufacturer may be held liable to a subpurchaser for sums paid to settle third-party personal-injury and property-damage claims allegedly caused by a defect in the component.
2. Whether Illinois should recognize strict products liability in tort (rather than contract-based implied warranty limitations) for defective products causing personal injury or property damage.

## Decision

- The Illinois Supreme Court affirmed the appellate court’s reinstatement of plaintiffs’ claims.
- The court adopted strict products liability in tort in Illinois.
- The court held that privity of contract is not required for strict liability claims by users or subpurchasers.
- The court held that a component manufacturer may be strictly liable when its component is defective, reaches the user without substantial change, and proximately causes injury or property damage.
- The court recognized that alleged damages could include reasonably incurred payments to repair third-party property and to settle third-party injury claims, if proximately caused by the defect.

## Legal Principles

- A manufacturer (including a component manufacturer) is strictly liable in tort when a product is in a defective, unreasonably dangerous condition when it leaves the manufacturer’s control and the defect proximately causes injury or property damage.
- Strict products liability does not depend on contractual privity between plaintiff and defendant.
- Liability extends beyond the immediate purchaser to foreseeable users and subpurchasers within the product’s chain of distribution and use.
- A component manufacturer is not categorically exempt from strict liability merely because its product is integrated into a finished product, if the component is expected to reach the user without substantial change and its defect causes harm.
- Recoverable damages in strict liability may include foreseeable property damage and personal-injury losses proximately resulting from the defect, including reasonable settlement payments and related expenses.

## Conclusion

Illinois recognized strict products liability in tort and permitted a subpurchaser to pursue a component-part manufacturer for damages allegedly caused by a defective component, including reasonably incurred payments to repair third-party property and to settle third-party injury claims, without requiring contractual privity.


Suvada v. White Motor Co., 210 N.E.2d 182 (Ill. 1965)