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Keywords

plaintiffdefendantliabilityappealsustainedstrict liability
defendantnegligenceliabilityappealsustainedstrict liability

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Technical Chemical Co. v. Jacobs, 480 S.W.2d 602

Facts

W. T. Jacobs purchased two cans of refrigerant from Joe Bain and sustained injuries when one can exploded. Jacobs claimed that the defendants failed to warn him about the dangers of connecting the can to the high-pressure side of the air conditioning compressor. The jury found that while the failure to warn exposed Jacobs to an unreasonable risk of harm, it did not find that this failure was a producing cause of his injuries. Jacobs had conflicting accounts of the incident, ultimately admitting that he had connected the can incorrectly before the explosion occurred.

Jacobs was a barber by trade and sustained injuries to his hand which interfered with his work.

Issue

Did the failure of Technical Chemical Company to warn Jacobs about the dangers of connecting the refrigerant can to the high-pressure side of the compressor constitute a producing cause of Jacobs' injuries?

The issue presented by this case is one of causation.

Rule

In strict liability cases, the plaintiff must prove that the defect in the product was the cause of the injuries sustained. A failure to warn can be considered a defect, but the plaintiff must establish that this failure was a producing cause of the injuries.

In strict liability cases, proof of negligence is excused; but, neither Section 402A, Supra, nor our former decisions have excused proof that the defect in the product was the cause of the injuries.

Analysis

The court analyzed the jury's findings, noting that while the failure to warn was recognized as exposing Jacobs to an unreasonable risk, the jury's refusal to find that this failure was a producing cause of the injuries was supported by evidence. Jacobs' inconsistent testimonies and the circumstances surrounding the explosion led the court to conclude that the jury could reasonably determine that a warning would not have changed Jacobs' actions.

The court of civil appeals ruled that the third special issue was irrelevant in a case in which the only defect asserted was the defendant's failure to warn a user who foreseeably would use the product as Jacobs did.

Conclusion

The Supreme Court reversed the Court of Civil Appeals' judgment in favor of Jacobs and remanded the case for further proceedings, emphasizing that Jacobs did not prove causation as a matter of law.

We reverse the judgment of the court of civil appeals which rendered judgment for Jacobs.

Who won?

Technical Chemical Company prevailed in the case because the Supreme Court found that Jacobs failed to establish that the lack of a warning was a producing cause of his injuries.

Technical Chemical, on the other hand, says that the only defect upon which Jacobs sued and submitted his case to the jury was the defendant's failure to give a warning that the can should not be connected to the high side of the compressor, and that the jury was entitled to conclude from the evidence that such a warning would have made no difference.

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