Madonna v. Harley Davidson, Inc.
1998 WL 130732, 708 A.2d 507 (1998)
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Rule of Law:
In a strict products liability action, evidence of a plaintiff's own conduct, such as intoxication or recklessness, is admissible for the limited purpose of proving that the plaintiff's conduct was the sole legal cause of the accident, thereby negating the element of causation against the manufacturer.
Facts:
- Charles Madonna was operating a motorcycle manufactured by Harley Davidson Inc., with Dolores Wilson as a passenger.
- The motorcycle was manufactured with a defective upper mounting bolt on the front wheel's brake caliper, which was subject to a recall.
- It was agreed that if this defective bolt broke during operation, it could cause the driver to lose control of the motorcycle.
- While Madonna was driving, an accident occurred, resulting in injuries to both Madonna and Wilson.
- After the accident, two witnesses smelled alcohol on Madonna's breath.
- A blood alcohol test revealed that Madonna had a blood alcohol concentration of .14% at the time he was operating the vehicle.
Procedural Posture:
- Charles Madonna and Dolores Wilson sued Harley Davidson Inc. in a trial court, asserting claims based on a theory of strict liability.
- At trial, the court permitted Harley Davidson to introduce evidence of Madonna's intoxication at the time of the accident over the plaintiffs' objections.
- The jury, answering a special interrogatory, returned a verdict finding that the motorcycle's defect was not a substantial factor in causing the accident.
- Appellants (Madonna and Wilson) filed post-trial motions challenging the admission of the intoxication evidence, which the trial court denied.
- The trial court entered a final judgment in favor of Appellee, Harley Davidson Inc.
- Appellants appealed the judgment to the Superior Court of Pennsylvania, an intermediate appellate court.
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Issue:
In a strict products liability action, is evidence of a plaintiff's intoxication and reckless operation of a vehicle admissible when offered by the defendant not to show comparative negligence, but to prove that the plaintiff's conduct was the sole cause of the injuries?
Opinions:
Majority - Del Sole, J.
Yes, evidence of a plaintiff's intoxication and reckless operation of a vehicle is admissible in a strict liability action when it is offered to prove that the plaintiff's conduct was the sole cause of the accident. While negligence concepts have no place in a strict liability action and cannot be used to compare fault, a plaintiff's conduct is relevant to the issue of causation. A plaintiff must prove that a product defect was a proximate cause of the injury. The defense is permitted to introduce evidence to negate this element by showing that the accident was solely the result of the user's conduct and was not related in any way to the product defect. Here, Harley Davidson offered evidence of Madonna's intoxication not to excuse the defect or argue contributory negligence, but to prove that his impaired driving was the sole cause of the crash, independent of the defective bolt. This is a valid inquiry into causation, and therefore, the evidence was properly admitted.
Analysis:
This decision clarifies a critical distinction in strict products liability law between the impermissible use of a plaintiff's negligence and the permissible use of a plaintiff's conduct to disprove causation. It solidifies the principle that while a defendant cannot argue comparative fault, it can present an 'all-or-nothing' defense arguing the plaintiff's actions were the sole, superseding cause of the harm. This provides a narrow but significant path for defendants to introduce evidence of user intoxication or recklessness, which can be highly prejudicial. Future litigation will likely focus on whether the user's conduct was merely a contributing factor (making the evidence inadmissible) or the sole cause of the injury.
