Friedman v. General Motors Corp.

Ohio Supreme Court
43 Ohio St.2d 209 (1975)

ELI5:

Rule of Law:

A plaintiff in a products liability case can establish a prima facie case of a manufacturing defect through circumstantial evidence from which a jury could reasonably infer that the defect existed at the time of manufacture and was the proximate cause of the plaintiff's injuries.

Facts:

Morton Friedman owned a 17-month-old Oldsmobile Toronado manufactured by defendant General Motors.
Prior to the incident, the Friedman family had never experienced any malfunctions with the car's transmission or gear shift indicator.
The family's practice was to always start the car with the gear selector in the 'Park' position.
While at a Sohio gas station, Morton Friedman started the Toronado, and it immediately accelerated upon ignition, causing an accident and injuries.
After the accident, the vehicle's gear shift indicator was found to be in the 'Drive' position.
Subsequent examinations by mechanics revealed that the Toronado could be started with the gear shift indicator in the 'Drive' position.
During one post-accident test, starting the car while in 'Drive' caused the front wheels to accelerate to a speed of 30 miles per hour in five seconds.

Procedural Posture:

The plaintiffs sued General Motors in a state trial court for damages arising from an automobile accident.
At the close of the plaintiffs' case at trial, the defendant, General Motors, moved for a directed verdict.
The trial court granted the defendant's motion for a directed verdict, preventing the case from going to the jury.
The plaintiffs, as appellants, appealed the trial court's decision to the Court of Appeals.
The Court of Appeals reversed the judgment of the trial court.
The defendant, General Motors, as appellant, appealed the reversal to the Supreme Court of Ohio.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does circumstantial evidence that a 17-month-old vehicle, with no history of malfunction or post-sale alteration to its transmission, suddenly accelerated upon ignition and was later found to start in 'Drive,' create a triable issue of fact for a jury regarding the existence of a manufacturing defect?

Opinions:

Majority - Paul W. Brown, J.

Yes. The plaintiffs' circumstantial evidence was sufficient to overcome a motion for a directed verdict because reasonable minds could differ as to whether the vehicle had a manufacturing defect. Construing the evidence most strongly in favor of the plaintiffs, a jury could reasonably infer that: 1) the vehicle's transmission and linkage adjustments were original and factory-set; 2) the defect would not have been discovered previously because the family always started the car in 'Park'; 3) the vehicle was in a forward gear upon ignition, causing the accident; and 4) post-accident tests confirmed the vehicle's ability to start while in 'Drive'. This chain of inferences supports the conclusion that a misaligned neutral start switch, existing since manufacture, was the direct and proximate cause of the accident.

Dissenting - Stern, J.

No. The plaintiffs failed to submit sufficient evidence from which a defect could be inferred, as their case rests on speculation rather than proof. The mere fact that an accident occurred is not evidence of a defect, especially when other possibilities like driver error or post-accident damage exist. Plaintiffs presented no direct physical evidence or expert testimony identifying a specific defect; their experts only testified that a malalignment was 'possible,' not 'probable.' Given the car's 17 months of trouble-free use, inferring that a defect existed at the time of manufacture without more positive proof is unreasonable.

Analysis:

This decision reinforces the viability of using circumstantial evidence to prove a defect in complex products liability cases. It lowers the evidentiary burden for plaintiffs to survive a directed verdict, establishing that they do not need to eliminate all other possible causes of an accident. The ruling signifies that a logical sequence of events pointing towards a product failure can be sufficient for a jury to infer the existence of a defect, even without direct expert testimony identifying the specific mechanical flaw. This precedent aids plaintiffs who may lack the resources or ability to conduct a forensic analysis of a product that has been damaged or destroyed.

Gunnerbot

AI-powered case assistant

Loaded: Friedman v. General Motors Corp. (1975)

Try: "What was the holding?" or "Explain the dissent"