Hatch v. Ford Motor Co.
329 P.2d 605, 163 Cal.App.2d 393, 1958 Cal. App. LEXIS 1509 (1958)
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Rule of Law:
A manufacturer's duty is to make a product safe for its intended use, not to design a product that is safe for a person to collide with while the product is stationary and being used properly. A violation of a safety statute only creates liability toward the class of persons and for the type of hazard the statute was designed to protect against.
Facts:
- A motor vehicle was manufactured and sold by the defendant.
- The vehicle was equipped with a pointed radiator ornament, approximately 9.5 inches long, fastened to the front and center of the automobile over the radiator.
- On June 30, 1955, this automobile was parked at the edge of Stansbury Avenue.
- Charles Hatch, a six-year-old child, was walking along Stansbury Avenue, where there were no sidewalks.
- Hatch proceeded toward the front of the parked automobile and collided with it.
- The radiator ornament pierced Hatch's left eyeball, causing the loss of his eye.
Procedural Posture:
- Charles Terrance Hatch and his father (plaintiffs) filed a second amended complaint against the automobile manufacturer (defendant) in the trial court.
- The defendant filed a demurrer, arguing the complaint failed to state a valid cause of action.
- The trial court sustained the defendant's demurrer.
- The plaintiffs failed to amend their complaint within the time granted by the court.
- The trial court issued an order dismissing the action.
- The plaintiffs (appellants) appealed the dismissal to this intermediate appellate court.
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Issue:
Does a motor vehicle manufacturer have a legal duty to design its vehicles to be safe for a person to collide with while the vehicle is lawfully parked, either under a general theory of negligence or a specific state statute prohibiting certain radiator ornaments?
Opinions:
Majority - Nourse, J. pro tem.
No. A motor vehicle manufacturer does not have a legal duty to design its vehicles to be safe for a person to collide with while the vehicle is lawfully parked. The court reasoned that a manufacturer's duty is limited to ensuring a product is safe for its intended use, which for a car includes driving and being parked. There is no duty to anticipate and protect against the risk of a person colliding with a stationary, properly parked vehicle. To impose such a duty would effectively make juries the 'arbiters of the design of automobiles' after an accident occurs, judging functional parts like headlights or antennas based on whether an alternative design could have prevented a specific injury. Furthermore, the statute prohibiting certain radiator ornaments (Vehicle Code § 683) was intended to protect people from the hazards of a car in motion on a highway, not to protect individuals who collide with an inert, parked object. Therefore, Hatch was not within the class of persons the statute was designed to protect, and the hazard was not one the statute was designed to prevent.
Analysis:
This case establishes a significant limitation on a manufacturer's duty in design defect cases under product liability law. It distinguishes between the duty to make a product safe for its intended purpose and a much broader, rejected duty to make it safe against all foreseeable external interactions, such as a person colliding with it. This decision represents a traditional view of liability that predates the modern 'crashworthiness' doctrine, which later imposed a duty on manufacturers to design vehicles that are reasonably safe for occupants during a collision. The court's reasoning prevents an expansion of liability that would allow juries to second-guess nearly every design choice on a vehicle after an accident.
