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Keywords

tortplaintiffdefendantnegligenceliabilityappealtrialsummary judgmentproduct liability
tortplaintiffdefendantliabilityappealtrialsummary judgmentproduct liability

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McCoy v. American Suzuki Motor Corp., 136 Wash.2d 350, 961 P.2d 952, Prod.Liab.Rep. (CCH) P 15,356

Facts

On a cold November evening, James McCoy stopped to assist after a Suzuki Samurai rolled off the roadway. After helping the injured driver, he was asked by a trooper to direct traffic and was positioned on the highway with flares. While walking back to his car, he was struck by a hit-and-run vehicle. McCoy filed a complaint against multiple parties, including Suzuki, alleging that the vehicle's defects caused the accident and his subsequent injuries while acting as a rescuer.

At 5:00 p.m. on a cold November evening James McCoy drove eastbound on Interstate 90 outside Spokane as the car which preceded him, a Suzuki Samurai, swerved off the roadway and rolled. McCoy stopped to render assistance, finding the driver seriously injured.

Issue

1) Whether the rescue doctrine may be invoked in a product liability action; 2) Whether a plaintiff asserting a claim as a rescuer under the rescue doctrine must still prove his injuries were proximately caused by the defendant's allegedly tortious conduct; 3) Whether the alleged fault of the defendant was the proximate cause of the plaintiff's injuries.

The issues are (1) whether the rescue doctrine may be invoked in a product liability action; (2) whether a plaintiff asserting a claim as a rescuer under the rescue doctrine must still prove his injuries were proximately caused by defendant's allegedly tortious conduct; and, if so, (3) whether the alleged fault of this defendant was the proximate cause of this plaintiff's injuries.

Rule

The rescue doctrine allows an injured rescuer to sue the party that caused the danger requiring the rescue. A rescuer must show that the defendant's negligence caused the peril and that the rescuer acted with reasonable care. The rescuer must also prove that the defendant's conduct proximately caused his injuries.

The rescue doctrine is invoked in tort cases for a variety of purposes in a variety of scenarios. The doctrine, as here asserted, allows an injured rescuer to sue the party which caused the danger requiring the rescue in the first place.

Analysis

The court determined that the rescue doctrine applies to product liability actions, allowing McCoy to pursue his claim against Suzuki. It emphasized that while the rescuer must show that the defendant's wrongdoing proximately caused his injuries, the question of whether Suzuki's alleged fault was the proximate cause of McCoy's injuries was a factual issue for the jury to decide. The court found that the foreseeability of the intervening cause, in this case, was sufficiently close to warrant a jury's consideration.

We conclude the rescue doctrine may be invoked in a product liability action. We also conclude the rescuer must show the defendant's wrongdoing proximately caused his injuries.

Conclusion

The Supreme Court of Washington affirmed the Court of Appeals' decision, allowing McCoy's case to proceed to trial. The court held that the rescue doctrine applies in product liability cases and that the question of proximate cause should be determined by a jury.

Affirmed and remanded.

Who won?

James McCoy prevailed in the appeal as the court reversed the summary judgment in favor of Suzuki, allowing his case to proceed to trial based on the application of the rescue doctrine.

The Court of Appeals thus concluded McCoy alleged sufficient facts to avoid summary judgment of dismissal and, accordingly, remanded for trial.

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