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Keywords

plaintiffnegligenceliabilityduty of care

plaintiffdefendanttrialcorporationduty of care

Related Cases

MacPherson v. Buick Motor Co., 217 N.Y. 382, 111 N.E. 1050, L.R.A. 1916F, 696, Am.Ann.Cas. 1916C, 440

Facts

The plaintiff was injured when a wheel of an automobile manufactured by Buick Motor Company collapsed while he was in the car. The wheel, made of defective wood, was purchased from another manufacturer and was not constructed by Buick. Evidence suggested that reasonable inspection could have revealed the defect, and there was no claim that Buick knew of the defect or concealed it. The case was brought as a negligence action by the plaintiff, who was a subvendee of the automobile.

The plaintiff was injured in consequence of the collapse of a wheel of an automobile manufactured by the defendant corporation which sold it to a firm of automobile dealers in Schenectady, who in turn sold the car to the plaintiff.

Issue

Did the manufacturer owe a duty of care to the plaintiff, who was not the immediate purchaser of the automobile, in light of the defective wheel that caused the injury?

The question to be determined is whether the defendant owed a duty of care and vigilance to any one but the immediate purchaser.

Rule

A manufacturer has a duty to ensure that its products are safe for use by consumers, even if the defect is in a component part supplied by another manufacturer, particularly when the product is inherently dangerous or likely to cause harm if defective.

An automobile is not an inherently dangerous article.

Analysis

The court applied the principle established in Thomas v. Winchester, which holds that a manufacturer can be liable for negligence if the product is inherently dangerous or if it is likely to cause harm when negligently constructed. The court found that the automobile, designed to operate at high speeds, posed a danger if its components were defective. The manufacturer was deemed to have a duty to inspect the product and ensure its safety, extending liability beyond the immediate purchaser to include the ultimate user.

We hold, then, that the principle of Thomas v. Winchester is not limited to poisons, explosives, and things of like nature, to things which in their normal operation are implements of destruction.

Conclusion

The court affirmed the judgment in favor of the plaintiff, holding that the manufacturer was liable for the injuries caused by the defective wheel, as it had a duty to ensure the safety of its product for all users.

The judgment should be affirmed.

Who won?

The plaintiff prevailed in the case because the court found that the manufacturer had a duty to ensure the safety of the automobile, which was not fulfilled due to the defective wheel.

The theory upon which the case was submitted to the jury by the learned judge who presided at the trial was that, although an automobile is not an inherently dangerous vehicle, it may become such if equipped with a weak wheel.

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