## Facts

- Williams worked as a security guard at a restaurant and was issued a portable two-way radio manufactured by RCA to contact police or obtain assistance.
- During an on-duty robbery, Williams attempted to use the radio to summon help, but the radio allegedly malfunctioned and did not work.
- Unable to call for backup, Williams attempted to apprehend the robber himself.
- The robber shot and seriously injured Williams.
- Williams sued RCA under strict products liability, alleging the radio was defective and unreasonably dangerous because it failed to function when needed, and that this failure proximately caused his injuries.
- The trial court dismissed the complaint for failure to state a cause of action, and Williams appealed.

## Issues

1. Whether a strict products-liability complaint states a claim where the alleged defect is a two-way radio’s failure to function during an armed robbery and the plaintiff is then shot while confronting the robber.
2. Whether the robber’s intentional shooting is a superseding, intervening cause that, as a matter of law, breaks proximate causation between the alleged product defect and the plaintiff’s injuries.

## Decision

- The appellate court affirmed the dismissal for failure to state a cause of action.
- The court treated the radio’s alleged malfunction as, at most, a factual circumstance leading to the encounter, not a legally sufficient proximate cause of the gunshot injury.
- The robber’s intentional criminal act was held to be an intervening, superseding cause that cut off RCA’s strict-liability responsibility.
- The harm suffered (being shot) was outside the class of risks that made the radio’s alleged nonfunction “unreasonably dangerous” for purposes of strict products liability.

## Legal Principles

- A strict products-liability plaintiff must plead a defective condition that is unreasonably dangerous, that existed when the product left the manufacturer’s control, and that proximately caused the injury.
- Proximate cause limits liability to harms that fall within the scope of risks created by the alleged defect; “but for” causation alone is insufficient.
- An independent, intentional criminal act by a third party may constitute a superseding cause that breaks the causal chain as a matter of law, particularly where the resulting harm is not a reasonably foreseeable consequence of the product defect.
- A product’s failure to perform a protective or safety-related function does not, without more, make the manufacturer strictly liable for injuries inflicted by a third party’s violent criminal conduct.

## Conclusion

The court held that the complaint did not state a strict products-liability claim because the radio’s alleged failure to work did not proximately cause Williams’s gunshot injury, and the robber’s intentional shooting was a superseding criminal act outside the risks that made the product allegedly defective and unreasonably dangerous.


Williams v. RCA Corp., 376 N.E.2d 37 (Ill. App. Ct. 1978)