Greenman v. Yuba Power Products, Inc.
59 Cal. 2d 57 (1963)
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Rule of Law:
A manufacturer is strictly liable in tort when an article it places on the market, knowing that it is to be used without inspection for defects, proves to have a defect that causes injury to a human being.
Facts:
- Plaintiff Greenman saw a Shopsmith, a combination power tool, demonstrated by a retailer and studied a brochure prepared by the manufacturer, Yuba Power Products, Inc.
- In 1955, Greenman's wife purchased a Shopsmith and gave it to him as a Christmas gift.
- In 1957, Greenman purchased attachments to use the Shopsmith as a lathe to shape a large piece of wood.
- While Greenman was using the lathe, the piece of wood suddenly flew out of the machine and struck him on the forehead, inflicting serious injuries.
- Expert testimony indicated that the accident was caused by a design defect, specifically inadequate set screws that became loose due to normal vibration.
- Approximately 10 and a half months after his injury, Greenman gave written notice of the claimed breaches of warranties to both the retailer and the manufacturer.
Procedural Posture:
- Plaintiff Greenman sued the retailer and the manufacturer, Yuba Power Products, Inc., in a California trial court for damages, alleging negligence and breaches of warranties.
- Following a trial, the court submitted to the jury claims of implied warranty breach against the retailer, and claims of negligence and express warranty breach against the manufacturer.
- The jury returned a verdict in favor of the retailer, but found in favor of Greenman against the manufacturer for $65,000.
- The trial court denied the manufacturer's motion for a new trial and entered judgment on the verdict.
- The manufacturer, Yuba Power Products, Inc. (appellant), appealed the judgment to the Supreme Court of California.
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Issue:
Is a manufacturer strictly liable in tort for injuries caused by a defect in its product, even when the injured party did not have a direct contractual relationship with the manufacturer and did not provide timely notice of breach of warranty?
Opinions:
Majority - Traynor, J.
Yes. A manufacturer is strictly liable in tort when it places a defective product on the market that causes injury. The court reasoned that the traditional rules of sales warranties, including the requirement of timely notice of breach, are designed for commercial transactions between parties in a contractual relationship and are inappropriate for protecting consumers injured by defective products. The court established that liability in such cases is not governed by the law of contract warranties but by the law of strict liability in tort. The purpose of this liability is to ensure that the costs of injuries from defective products are borne by the manufacturers who place them on the market, rather than by injured consumers who are powerless to protect themselves. Therefore, a plaintiff need only prove they were injured while using the product as intended as a result of a defect in design and manufacture, of which the plaintiff was not aware, that made the product unsafe for its intended use.
Analysis:
This landmark decision established the doctrine of strict products liability in tort, fundamentally shifting the legal landscape for consumer protection. By moving the basis of liability from contract (warranty) to tort, the court eliminated the traditional defenses of lack of privity and failure to provide timely notice, which had often barred consumer claims. This case set the precedent for Section 402A of the Restatement (Second) of Torts and has been widely adopted, making it significantly easier for individuals injured by defective products to recover damages from manufacturers. Its impact is a heightened duty on manufacturers to ensure product safety.
