General Motors Corp. v. Sanchez
997 S.W.2d 584 (1999)
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Rule of Law:
A plaintiff's negligence, other than the mere failure to discover or guard against a product defect, is subject to the doctrine of comparative responsibility, which reduces the plaintiff's recovery in a strict products liability action in proportion to their assessed fault.
Facts:
- Lee Sanchez, Jr. owned a 1990 Chevy pickup truck manufactured by General Motors (G.M.).
- In March 1993, Sanchez drove his truck into a corral and exited the vehicle to close the gate.
- Sanchez apparently mis-shifted the transmission into an intermediate position between Park and Reverse, known as 'hydraulic neutral.'
- After he exited the vehicle, the gearshift slipped into Reverse, causing the truck to roll backward.
- The open driver's side door pinned Sanchez against the corral gate, trapping him between the door pillar and the gate.
- The truck's owner's manual described several safety measures to prevent the vehicle from moving when parked, such as setting the parking brake, none of which Sanchez performed.
- As a result of being pinned, Sanchez suffered a severed artery in his right arm and bled to death.
Procedural Posture:
- The Sanchez family (plaintiffs) sued General Motors Corporation (defendant) in a Texas state trial court for negligence, products liability, and gross negligence.
- A jury found G.M. liable for a design defect and negligence, but also found that Sanchez was fifty percent responsible for the accident.
- The trial court disregarded the jury's comparative responsibility finding and entered a judgment for the plaintiffs for $8.5 million in actual and punitive damages.
- G.M. (appellant) appealed to the court of appeals.
- A panel of the court of appeals, and subsequently the court of appeals sitting en banc, affirmed the trial court's judgment.
- G.M. (petitioner) then appealed to the Supreme Court of Texas.
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Issue:
Does a plaintiff's negligence, unrelated to the failure to discover or guard against a product defect, subject their recovery in a strict products liability action to the statutory comparative responsibility scheme?
Opinions:
Majority - Justice Gonzales
Yes, a plaintiff's negligence that is more than a mere failure to discover or guard against a product defect subjects their recovery to comparative responsibility. While a consumer has no legal duty to actively search for or anticipate product defects, they are not relieved of the general duty to act with reasonable care for their own safety. Conduct that violates this duty of ordinary care, such as failing to follow standard safety precautions unrelated to the specific defect, is distinct from the protected failure to discover the defect itself. In this case, Sanchez's failure to take reasonable precautions to secure his vehicle before exiting it—such as setting the parking brake or ensuring the gear was fully in Park—was negligence independent of the transmission defect. Therefore, the jury's finding that Sanchez was fifty percent responsible for the accident must be applied to reduce the damages awarded to the plaintiffs.
Analysis:
This decision significantly clarifies the application of comparative responsibility in Texas products liability law by narrowing a key defense for plaintiffs. It effectively limits the precedent set in Keen v. Ashot Ashkelon, Ltd., which had been interpreted to shield plaintiffs from nearly all forms of contributory negligence short of knowingly assuming the risk. By distinguishing between the 'mere failure to discover a defect' and other forms of ordinary negligence, the court allows juries to apportion fault to plaintiffs who fail to take reasonable safety precautions. This holding empowers defendants in product liability cases to reduce damage awards by introducing evidence of the plaintiff's general carelessness, thereby balancing the policy of protecting consumers with the principle that individuals are responsible for their own reasonable care.
