McCabe v. Liggett Drug Co. Inc.
330 Mass. 177, 112 N.E.2d 254, 1953 Mass. LEXIS 440 (1953)
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Rule of Law:
A product that is so defectively designed that it is dangerous when used for its ordinary purpose is not of merchantable quality, and the seller is liable for breaching the implied warranty of merchantability.
Facts:
- On or about May 20, 1949, an agent for the plaintiff, Huwe, purchased a metal coffee maker called 'Lucifer ‘Lifetime’' from the defendant's store in a sealed cardboard carton.
- Huwe had seen the coffee maker on display a week earlier and was purchasing it at the plaintiff's request.
- Huwe specified he wanted 'one of the metal coffee makers' he had seen on sale, confirming with the clerk that it was the correct one.
- The plaintiff used the coffee maker two or three times and noticed that water was slow to rise into the upper bowl.
- On June 9, 1949, while the plaintiff was using the appliance according to the included written instructions, it stopped working properly and then exploded.
- The explosion threw hot water and coffee grounds on the plaintiff, causing burns, and sent the upper bowl flying across the room.
Procedural Posture:
- The plaintiff brought an action of contract against the defendant in the trial court to recover for personal injuries, alleging breaches of implied warranties of fitness and merchantability.
- A jury returned a verdict for the plaintiff.
- The trial court judge, on the defendant's motion, entered a verdict for the defendant under leave reserved (a form of judgment notwithstanding the verdict).
- The plaintiff appealed the judge's decision to enter a verdict for the defendant.
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Issue:
Does a coffee maker that violently explodes during its ordinary and intended use due to a latent design defect breach the seller's implied warranty of merchantability?
Opinions:
Majority - Williams, J.
Yes. A product that explodes during normal use because of a design imperfection is not reasonably fit for its intended purpose and therefore is not merchantable. The sale was a sale by description, which carries an implied warranty that the product is of merchantable quality, meaning it is reasonably suitable for the ordinary uses for which such goods are sold. The fact that the coffee maker violently burst apart during proper use is itself evidence of a defective condition. A jury could reasonably conclude, even without expert testimony, that the filter's design provided an inadequate outlet for steam pressure, which, when combined with clogging from coffee grounds, caused the explosion. Because this design defect would not be obvious to an ordinary person upon inspection, the plaintiff did not waive her right to rely on the implied warranty.
Analysis:
This case solidifies the principle that the implied warranty of merchantability extends to a product's design, not just its manufacture. It establishes that a product's catastrophic failure during normal use can serve as compelling circumstantial evidence of a breach, allowing a jury to infer a defect without the need for expert testimony. The decision protects consumers by affirming that they can rely on a seller's implied promise of a product's basic safety and fitness for its intended purpose, especially when a defect is not discoverable through a reasonable inspection.
