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Keywords

plaintiffdamagesnegligenceliabilityappealstrict liability
plaintiffdamagesnegligenceliabilityappealstrict liability

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General Motors Corp. v. Sanchez, 997 S.W.2d 584, Prod.Liab.Rep. (CCH) P 15,620, 42 Tex. Sup. Ct. J. 969

Facts

Lee Sanchez, Jr. was killed in March 1993 when his 1990 Chevy pickup truck rolled backward while he was attempting to close a corral gate. The truck's transmission had a defect that allowed it to slip into a position known as 'hydraulic neutral,' which led to the truck rolling backward and pinning Sanchez against the gate. The plaintiffs argued that the truck's design was defective and that General Motors failed to provide adequate warnings about the risks associated with the transmission. The jury found General Motors negligent and awarded damages, while also attributing 50% of the responsibility for the accident to Sanchez.

Sanchez drove his truck into the corral and stopped to close the gate. He mis-shifted into what he thought was Park, but what was actually an intermediate, 'perched' position between Park and Reverse where the transmission was in 'hydraulic neutral.'

Issue

When does the doctrine of comparative responsibility apply in a products liability case?

The principal question in this case is when does the doctrine of comparative responsibility apply in a products-liability case.

Rule

Comparative responsibility applies in strict liability if a plaintiff's negligence is something other than the mere failure to discover or guard against a product defect.

We conclude that: (1) comparative responsibility applies in strict liability if a plaintiff's negligence is something other than the mere failure to discover or guard against a product defect.

Analysis

The court determined that Sanchez's actions constituted negligence beyond merely failing to guard against a product defect, as he did not follow safety measures outlined in the truck's owner's manual. This negligence was sufficient to apply comparative responsibility, allowing the jury's finding that Sanchez was 50% responsible for the accident to reduce the damages awarded to the plaintiffs.

The jury found that Sanchez was fifty percent responsible for his accident. G.M. argues that this finding should be applied to reduce its liability for damages whether in negligence or strict liability.

Conclusion

The Supreme Court reversed the court of appeals' judgment and rendered judgment for the plaintiffs' actual damages, as reduced by the jury's comparative responsibility finding.

Therefore, we reverse the court of appeals' judgment and render judgment for the plaintiffs' actual damages, as reduced by the jury's comparative responsibility finding.

Who won?

The plaintiffs prevailed in the case because the court found sufficient evidence of a design defect in the truck's transmission and that Sanchez's negligence did not absolve General Motors of liability.

The jury rejected G.M.'s theories and found that G.M. was negligent, the transmission was defectively designed, and G.M.'s warning was so inadequate as to constitute a marketing defect.

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