Kaneko v. Hilo Coast Processing
654 P.2d 343, 1982 Haw. LEXIS 238, 65 Haw. 447 (1982)
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Rule of Law:
A prefabricated building sold in component parts is a 'product' for which its manufacturer can be held strictly liable for defects. Furthermore, the doctrine of comparative negligence merges with strict products liability, meaning a plaintiff's recovery will be reduced in proportion to their own percentage of fault.
Facts:
- Hilo Coast Processing Company hired Mutual Welding Co., Ltd. to manufacture and fabricate the steel components for a prefabricated mill building.
- Central Pacific Boiler and Piping was hired to erect the building, employing Milton Kaneko as an ironworker.
- Kaneko's job required him to connect horizontal steel beams (girts) to vertical columns by climbing the structure and standing on the girt he had just connected to install the next one above it.
- On August 16, 1973, while Kaneko was standing on the second girt to connect the third, the girt he was standing on came loose.
- The failure occurred because the steel clip connecting the girt to the column had only been temporarily 'tack welded' by Mutual Welding, rather than being fully and permanently welded.
- Kaneko fell approximately 10 to 20 feet to the ground, sustaining severe back injuries that permanently prevented him from returning to his work as an ironworker.
Procedural Posture:
- Milton Kaneko sued Mutual Welding Co., Ltd. and Hilo Coast Processing in the Third Circuit Court of Hawaii (the trial court).
- A jury returned a special verdict finding Mutual Welding liable on theories of negligence, strict liability, and breach of warranty.
- The jury found Kaneko to be 27% contributorily negligent and Mutual Welding to be 73% at fault.
- The trial court entered judgment for Kaneko but reduced the total damage award by 27% to reflect his comparative negligence.
- Mutual Welding filed a Motion for a New Trial, which was denied.
- Kaneko filed a Motion for Judgment Notwithstanding the Verdict, arguing his award should not be reduced, which was also denied.
- Mutual Welding appealed the judgment to the Supreme Court of Hawaii, arguing strict liability should not apply, and Kaneko cross-appealed, arguing comparative negligence should not reduce his award.
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Issue:
Does a plaintiff's own negligence, assessed under principles of comparative negligence, reduce their recovery in a strict products liability claim?
Opinions:
Majority - Ogata, J.
Yes, a plaintiff's own negligence reduces their recovery in a strict products liability claim because the doctrine of comparative negligence merges with the doctrine of strict liability. The court first addressed whether strict liability applied at all, concluding that a prefabricated building is a 'product.' The court declined to establish a rigid definition of 'product,' opting for a case-by-case analysis guided by public policy, which supports extending liability to manufacturers of defective building components. On the primary issue, the court rejected arguments that the fault-based concept of negligence is incompatible with the no-fault concept of strict liability, stating that 'fairness and equity are more important than conceptual and semantic consistency.' The merger promotes a more just result by apportioning damages based on the fault of all parties, rather than imposing an all-or-nothing outcome. It also harmonizes the treatment of plaintiff's fault in negligence and strict liability actions, and it does not substantially undermine the manufacturer's incentive to produce safe products.
Analysis:
This decision officially merges the doctrines of comparative negligence and strict products liability in Hawaii, aligning the jurisdiction with a modern trend exemplified by courts in California. By doing so, the court shifted from a harsh 'all or nothing' system for plaintiff's fault (like assumption of risk) to a more equitable apportionment of damages. The ruling also broadens the definition of 'product' to include large, assembled structures like prefabricated buildings, signaling that the scope of strict liability will be interpreted flexibly and expanded based on public policy rather than on rigid, pre-existing categories. This dual holding significantly impacts tort litigation by creating a unified system for handling plaintiff's fault and expanding the reach of product liability law.
