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lawsuitplaintiffnegligenceliabilitytestimonysummary judgmentsustainedstrict liability
negligenceliabilityappealtrialsustainedstrict liability

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Camacho v. Honda Motor Co., Ltd., 741 P.2d 1240, Prod.Liab.Rep. (CCH) P 11,485

Facts

In March 1978, Jaime Camacho purchased a new 1978 Honda Hawk motorcycle. In May 1978, while riding through an intersection, he collided with an automobile, resulting in serious leg injuries. Camacho and his wife filed a lawsuit against Honda, claiming that the motorcycle was defectively designed because it lacked 'crash bars' that could have mitigated his injuries. Expert testimony indicated that such safety devices were feasible and available at the time of the accident.

In March 1978, Jaime Camacho (Camacho) purchased a new 1978 Honda Hawk motorcycle, model CV400T2, from a Honda dealer. In May 1978, while driving the motorcycle through an intersection, Camacho collided with an automobile and sustained serious leg injuries.

Issue

Whether the absence of leg protection devices on a motorcycle constitutes a design defect that renders the motorcycle in a defective condition unreasonably dangerous under Colorado law.

The issue before the court is what test should apply in determining whether a product has a design defect causing it to be in a defective condition that is unreasonably dangerous.

Rule

A manufacturer may be liable in negligence or strict liability for design defects that enhance injuries sustained in an accident, and the obviousness of a danger does not serve as a defense in a products liability claim.

Under this doctrine, a motor vehicle manufacturer may be liable in negligence or strict liability for injuries sustained in a motor vehicle accident where a manufacturing or design defect, though not the cause of the accident, caused or enhanced the injuries.

Analysis

The court analyzed the evidence presented, including expert testimony that indicated the feasibility of installing crash bars on the motorcycle. It concluded that the absence of such safety features could render the motorcycle unreasonably dangerous, as the manufacturer had a duty to provide reasonable safety measures. The court found that the lower courts had applied an incorrect standard by focusing on consumer contemplation rather than the actual safety of the product.

The record contains some evidence to support the conclusion that Honda could have provided crash bars at an acceptable cost without impairing the motorcycle's utility or substantially altering its nature and Honda's failure to do so rendered the vehicle unreasonably dangerous under the applicable danger-utility test.

Conclusion

The Supreme Court reversed the lower court's decision and remanded the case for further proceedings, indicating that material questions of fact existed regarding the motorcycle's safety.

The judgment is reversed, and the case is remanded to the Court of Appeals with directions to remand the case to the trial court for further proceedings consistent with the views expressed in this opinion.

Who won?

The plaintiffs, Jaime and Kathleen Camacho, prevailed as the Supreme Court reversed the summary judgment in favor of Honda, allowing their claims to proceed.

The Camachos proffered evidence that the Honda Hawk motorcycle could have been equipped with crash bars which would mitigate injuries in low-speed, angled-impact collisions such as the one in which Camacho was involved.

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