Campbell v. General Motors Corp.
32 Cal. 3d 112, 184 Cal. Rptr. 891, 649 P.2d 224 (1982)
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Rule of Law:
In a products liability action alleging a design defect, a plaintiff can establish a prima facie case sufficient to withstand a nonsuit motion by presenting circumstantial evidence that a design feature (or lack thereof) was a proximate cause of injury under either the consumer expectation test or the risk-benefit test, even without expert testimony, if the matter is within the common experience of ordinary consumers.
Facts:
- On August 21, 1973, Florence L. Campbell, a 62-year-old woman, was injured while riding a bus manufactured by General Motors Corporation and owned by the City and County of San Francisco.
- Campbell was seated in the first forward-facing single seat on the right side of the bus, which faced the side of a lateral-facing double seat.
- Unlike other forward-facing seats, Campbell's seat lacked a horizontal metal 'grab bar' at shoulder level in front of it and also lacked a vertical metal pole within reach.
- As the bus entered an intersection, the bus driver 'turned very sharply' and 'kept gaining speed.'
- Campbell was propelled from her seat, reached for something to hold onto but found nothing, and was thrown to the floor on the opposite side, falling on her left hip.
- Campbell was hospitalized for approximately 18 days and used crutches for several months, suffering serious continuing medical problems as a result of the accident.
Procedural Posture:
- Plaintiff Florence L. Campbell filed suit against General Motors Corporation and the City and County of San Francisco, alleging negligence against the City and a design defect (lack of handrails/guardrails) against General Motors.
- Campbell settled her claim against the City, so the trial proceeded only against General Motors.
- After Campbell presented her evidence during her case-in-chief, General Motors moved for a judgment of nonsuit, contending that Campbell failed to introduce sufficient evidence of design defect or proximate cause.
- The trial court granted General Motors' motion for nonsuit, dismissed the jury, and entered judgment for General Motors.
- Campbell appealed the trial court's judgment.
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Issue:
Does a plaintiff in a products liability action alleging a design defect, particularly the absence of a safety device, present sufficient evidence to establish a prima facie case of causation and defect under the Barker tests to withstand a motion for nonsuit, even without expert testimony, when the subject matter is within common lay experience?
Opinions:
Majority - Bird, C. J.
Yes, a plaintiff in a products liability action alleging a design defect, particularly the absence of a safety device, presents sufficient evidence to establish a prima facie case of causation and defect under the Barker tests to withstand a motion for nonsuit, even without expert testimony, when the subject matter is within common lay experience. The California Supreme Court reversed the trial court's grant of nonsuit, finding that Campbell presented sufficient evidence to establish a prima facie case under both prongs of the Barker v. Lull Engineering Co. design defect test. A motion for nonsuit should only be granted if the plaintiff's evidence, when viewed most favorably to the plaintiff and indulging all legitimate inferences, cannot support a jury verdict in their favor. Under the second Barker test (risk-benefit), a plaintiff must show that the injury was proximately caused by the product's design. The Court reasoned that Campbell's testimony that she was thrown from her seat and reached for but found nothing to grab, combined with photographic evidence of the bus's design (specifically the absence of a grab bar or pole in front of her seat), was sufficient for a jury to reasonably infer that a handrail or guardrail within her reach would have prevented the accident. This is a question of common knowledge, not requiring expert testimony, similar to how the absence of a seatbelt can be commonly understood as a cause of injury (McNeil v. Yellow Cab Co.). Once such a prima facie showing of causation is made, the burden of proof shifts to the defendant under Barker's second prong to show the product is not defective, given the manufacturer's superior knowledge of design feasibility and cost. Furthermore, the Court held that Campbell also presented sufficient evidence under the first Barker test (consumer expectation). Her testimony about the accident and the objective features of the bus, combined with the fact that public transportation is within common experience, allowed a jury to determine whether the bus met the ordinary safety expectations of consumers without expert testimony. Denying the benefit of reasonable inferences of proximate cause would frustrate the public policy of protecting victims of defective products.
Analysis:
This case clarifies the evidentiary burden for plaintiffs in California strict products liability design defect cases, particularly in overcoming a nonsuit motion. It reinforces the principle that a plaintiff does not need expert testimony or mathematical certainty to establish causation when the alleged design defect (e.g., absence of a safety device) and its potential causal link to the injury are matters of common experience for a lay jury. The decision emphasizes the pro-consumer policies underlying strict liability, ensuring that manufacturers bear the burden of proving a product is not defective under the risk-benefit test once a plaintiff makes a prima facie showing of causation. This makes it harder for manufacturers to avoid jury trials by claiming insufficient evidence, especially for simple, observable design issues.
