Cronin v. J.B.E. Olson Corp.
8 Cal. 3d 121, 104 Cal. Rptr. 433, 501 P.2d 1153 (1972)
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Rule of Law:
In a strict products liability action, the plaintiff is not required to prove that a product's defect made it 'unreasonably dangerous' to the user or consumer; the plaintiff must only prove that a defect in the manufacture or design of the product proximately caused the injury.
Facts:
- In 1957, Gravem-Inglis Bakery Co. (Gravem) purchased a Chevrolet bread delivery truck, which was sold by J.B.E. Olson Corporation (Olson).
- The truck was equipped with bread racks held in place by an aluminum safety hasp designed to prevent the trays from moving forward.
- On October 3, 1966, Cronin, a route salesman for Gravem, was driving the truck when another vehicle made a sudden turn, forcing Cronin's truck into a ditch.
- The collision caused the aluminum safety hasp to break.
- The loaded bread trays, no longer secured, slid forward, struck Cronin in the back, and propelled him through the windshield.
- Cronin sustained serious personal injuries as a result.
- An expert testified that the metal hasp was extremely porous and had a significantly lower tolerance to force than a non-flawed hasp.
Procedural Posture:
- Cronin sued J.B.E. Olson Corporation and others in a California trial court for personal injuries.
- The jury returned a verdict in favor of Cronin and against defendant Olson for $45,000.
- The trial court entered judgment on the verdict.
- J.B.E. Olson Corporation (appellant) appealed the judgment to the Supreme Court of California.
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Issue:
In a strict products liability action, does a plaintiff have the burden of proving that a product's defect made it 'unreasonably dangerous' to the user or consumer?
Opinions:
Majority - Sullivan, J.
No. In a strict products liability action, a plaintiff is not required to prove that a product defect was also 'unreasonably dangerous.' The standard set forth in Greenman v. Yuba Power Products, Inc. requires only that the plaintiff prove a defect in manufacture or design proximately caused the injury. The court traced the history of strict liability in California, noting that the 'unreasonably dangerous' requirement was introduced later by the Restatement (Second) of Torts § 402A and was not part of California's original formulation. The court rejected the Restatement's language because it 'rings of negligence' and would burden the plaintiff with proof of an element that complicates and undermines the purpose of strict liability, which is to relieve injured consumers from complex proof issues and to ensure manufacturers bear the costs of injuries from defective products.
Analysis:
This decision solidifies California's departure from the widely adopted Restatement (Second) of Torts § 402A standard for strict products liability. By eliminating the 'unreasonably dangerous' element, the California Supreme Court significantly lowered the burden of proof for plaintiffs in such cases. This ruling reinforces the judicial policy of shifting the cost of injuries from consumers to manufacturers, making California a more favorable jurisdiction for plaintiffs. The case focuses the legal inquiry directly on the existence of a 'defect' and 'causation,' avoiding negligence-based concepts like consumer expectations that are embedded in the 'unreasonably dangerous' language.
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