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Keywords

plaintiffliabilitytrialwilljury trialjury instructions

tortplaintifftrialverdictwillsustainedjury instructionsverdict form

Related Cases

Collins v. Navistar, Inc., 214 Cal.App.4th 1486, 155 Cal.Rptr.3d 137, Prod.Liab.Rep. (CCH) P 19,090, 13 Cal. Daily Op. Serv. 3567, 2013 Daily Journal D.A.R. 4169

Facts

William F. Collins, a commercial truck driver, was severely injured when a 2.5-pound piece of concrete was thrown by a 15-year-old, Joshua Daniel, while he was driving on Interstate Highway 5. The concrete penetrated the windshield of Collins' truck, causing him to lose control and crash. Collins and his wife subsequently sued Navistar, the manufacturer of the truck, claiming that the windshield was defectively designed and failed to withstand such impacts. The trial court excluded evidence regarding alternative designs for the windshield, leading to a jury trial that ultimately ruled in favor of Navistar.

This action arises out of injuries plaintiff William F. Collins sustained while driving a big rig truck manufactured by Navistar, Inc. A 2.5–pound piece of concrete thrown by 15–year–old Joshua Daniel penetrated the windshield of the truck and struck William in the head.

Issue

Did the trial court err in instructing the jury on the foreseeability standard required for a strict products liability claim, particularly in light of the criminal nature of the act that caused the injury?

The trial court erred in instructing that a heightened foreseeability was required and the error was prejudicial because the special verdict form precluded the jury from considering whether the risk of chunks of concrete hitting the truck's windshield was a reasonably foreseeable road hazard.

Rule

A manufacturer is liable for injuries caused by a defect in the design or manufacture of its product if the product is used in a reasonably foreseeable manner, regardless of whether the harm was caused by a criminal act.

A manufacturer, distributor, or retailer is liable in tort if a defect in the manufacture or design of its product causes injury while the product is being used in a reasonably foreseeable way.

Analysis

The appellate court found that the trial court's instruction requiring a heightened foreseeability standard due to the criminal nature of the act was erroneous. The court emphasized that the foreseeability required pertains to the risk of harm, not the specific intervening act. The court concluded that the risk of objects striking windshields is a foreseeable hazard that manufacturers must consider in their designs.

Conclusion

The appellate court reversed the trial court's judgment in favor of Navistar and remanded the case for a new trial, stating that the jury should have been allowed to consider whether the risk of concrete chunks hitting the windshield was a reasonably foreseeable hazard.

We conclude the trial court erred in instructing that a heightened foreseeability was required and the error was prejudicial because the special verdict form precluded the jury from considering whether the risk of chunks of concrete hitting the truck's windshield was a reasonably foreseeable road hazard.

Who won?

The appellate court ruled in favor of the plaintiffs, reversing the previous judgment for Navistar due to errors in jury instructions regarding foreseeability.

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