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Keywords

contractlawsuitsettlementplaintiffdamagesliabilitystrict liability

settlementplaintiffliabilitystrict liability

Related Cases

Suvada v. White Motor Co., 32 Ill.2d 612, 210 N.E.2d 182, 2 UCC Rep.Serv. 762

Facts

Steven Suvada and John Konecnik, partners in a milk distribution business, purchased a used tractor unit from White Motor Company, which had a brake system manufactured by Bendix-Westinghouse Automotive Air Brake Company. On June 24, 1960, the brake system failed, leading to a collision with a Chicago Transit Authority bus, resulting in injuries to passengers and damage to both the bus and the tractor-trailer. The plaintiffs subsequently filed a lawsuit against both manufacturers to recover costs associated with repairs and settlements for personal injury claims.

On June 21, 1962, plaintiffs filed this action against White and Bendix to recover the costs they incurred in repairing their tractor-trailer unit, repairing the bus and in their settlement of personal injury claims by the bus passengers.

Issue

Whether the manufacturer of a component part (the brake system) is liable to a subpurchaser for damages incurred due to the defective condition of that component part, despite the lack of privity of contract.

Specifically, the question presented is whether the manufacturer of a component part is liable to a subpurchaser for sums of money the subpurchaser has paid to settle claims against him by persons who were injured and whose property was damaged as a result of the defective condition of the component part.

Rule

The court held that a manufacturer can be held strictly liable for injuries caused by a defective product, even if the injured party is not in privity of contract with the manufacturer.

The Appellate Court imposed strict liability on the theory of an implied warranty and held that lack of privity between plaintiffs and Bendix is no defense.

Analysis

The court applied the rule of strict liability by determining that Bendix, the manufacturer of the brake system, had not altered the product but merely installed it in the tractor unit. This lack of modification meant that Bendix was responsible for the defective condition of the brake system that led to the accident. The court emphasized that the principles of strict liability apply to manufacturers of component parts, thereby holding Bendix liable for the damages incurred by the plaintiffs.

Under these circumstances we see no reasons why Bendix should not come within the rule of strict liability.

Conclusion

The Supreme Court affirmed the Appellate Court's decision, ruling that Bendix was strictly liable for the damages resulting from the defective brake system.

The judgment of the Appellate Court is affirmed.

Who won?

The plaintiffs, Steven Suvada and John Konecnik, prevailed in the case because the court found that the manufacturer of the brake system was strictly liable for the damages caused by its defective product.

The plaintiffs allege that they were compelled to make the settlements. This negatives any question that they acted as volunteers.

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