Daniell v. Ford Motor Co., Inc.
581 F. Supp. 728, 38 U.C.C. Rep. Serv. (West) 464, 1984 U.S. Dist. LEXIS 18318 (1984)
Rule of Law:
A manufacturer is not liable under theories of strict products liability, negligence, or breach of warranty for injuries resulting from a product's unforeseeable misuse, particularly when the use is contrary to the product's ordinary purpose and the danger is obvious.
Facts:
- In 1980, Connie Daniell became locked inside the trunk of a 1973 Ford LTD automobile.
- Connie Daniell remained in the trunk for approximately nine days.
- Connie Daniell entered the trunk compartment because she felt "overburdened" and was attempting to commit suicide.
- The ordinary purposes of an automobile trunk are to transport, stow, and secure the spare tire, luggage, and other goods, and to protect these items from weather.
- Connie Daniell never considered the possibility of exiting from the inside of the trunk when she purchased the automobile.
Procedural Posture:
- Connie Daniell sued Ford Motor Company (the manufacturer) in the United States District Court for the District of New Mexico, alleging design defect, failure to warn, and breach of warranty.
- Ford Motor Company filed a Motion for Summary Judgment pursuant to F.R.Civ.P. 56(c).
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Issue:
Does a manufacturer have a duty to design an internal trunk release mechanism or warn against the dangers of being trapped inside a trunk when an individual intentionally uses the trunk compartment as a means to attempt suicide?
Opinions:
Majority - BALDOCK, District Judge
No, a manufacturer does not have a duty to design an internal trunk release or warn against the dangers of intentional self-entrapment for a use that is unforeseeable and contrary to the product's ordinary purpose. The court found that Connie Daniell's use of the trunk to attempt suicide was an unforeseeable use as a matter of law. Therefore, Ford Motor Company had no duty to design a mechanism to prevent this occurrence under strict products liability or negligence, as a manufacturer only has a duty to consider foreseeable risks. The court also held there was no duty to warn because the use was unforeseeable and the risk of being trapped in a trunk is obvious, and there is no duty to warn of known dangers. Regarding warranty claims, the court found no evidence of an express warranty concerning internal trunk exit. For implied warranty of merchantability, the trunk was fit for its ordinary purpose of storing goods, and Daniell's use was highly extraordinary. Finally, the claim for implied warranty of fitness for a particular purpose failed because Daniell admitted she did not rely on the seller's skill or judgment for such a purpose, nor did she consider the trunk mechanism for exit when purchasing the car.
Analysis:
This case significantly reinforces the principle that manufacturers are generally not liable for injuries arising from unforeseeable misuse of their products. It clarifies the scope of a manufacturer's duty to design and warn, limiting it to risks associated with ordinary and reasonably anticipated uses. Future cases involving product liability will likely refer to this precedent when determining the foreseeability of a product's use, particularly for highly unusual or self-harmful applications, potentially limiting manufacturers' exposure to liability in extreme circumstances of user misconduct.
