Midwestern VW Corporation v. Ringley
503 S.W.2d 745 (1973)
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Rule of Law:
In a strict products liability claim, the plaintiff bears the burden of introducing evidence sufficient to support a reasonable inference that the manufacturer's defect was the probable cause of the accident, not merely a possible cause among other potential explanations.
Facts:
- Wanda Ringley purchased a new Volkswagen automobile from Kelly Vance Motors.
- Shortly after the purchase, Ringley experienced the car pulling to the right when she applied the brakes abruptly.
- She returned the car to Kelly Vance Motors for repair of this issue on three separate occasions, and each time was told the problem was fixed.
- Eight days after the third repair attempt, Ringley was driving on a wet road and saw a pool of water ahead.
- When she applied the brakes, the right front wheel 'grabbed,' sending her car into a spin and causing it to strike a telephone pole, resulting in her severe injury.
- An examination of the vehicle after the accident by Ringley's witnesses revealed that the right-front brake drum was 'out of round' to a degree that exceeded factory specifications.
- These witnesses identified the 'out of round' brake drum as a defect from the manufacturing process.
Procedural Posture:
- Wanda Ringley sued Kelly Vance Motors, Inc., Volkswagenwerk Aktiengesell, Volkswagen of America, Inc., and Midwestern Volkswagen Corporation in the Hardin Circuit Court (trial court).
- The jury returned a verdict in favor of Wanda Ringley.
- The trial court entered a judgment against all defendants based on the jury's verdict.
- The trial court also entered a judgment for indemnity in favor of Kelly Vance Motors against the other Volkswagen defendants.
- Volkswagenwerk Aktiengesell (manufacturer), Volkswagen of America, Inc. (importer), and Midwestern Volkswagen Corporation (distributor) appealed the judgment to the reviewing appellate court.
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Issue:
Does a plaintiff in a strict products liability case meet the burden of proof for causation by establishing that a product defect was a possible cause of the accident, when other potential causes also exist?
Opinions:
Majority - Stephenson, J.
No. The doctrine of strict liability does not relieve a plaintiff from the burden of proving causation. To prevail, the plaintiff must introduce evidence showing that the product's defect was the probable cause of the accident, as distinguished from a mere possible cause. Here, Ringley’s own expert witnesses admitted on cross-examination that other conditions—such as dirt, water in the opposite brake lining, or improper adjustment—could also have caused the car to pull to the right. No witness for Ringley testified that the 'out of round' brake drum was the 'probable' cause of her accident. Without evidence establishing probability over possibility, a jury's verdict would be based on speculation or surmise, which is not permissible.
Dissenting - Palmore, C.J.
Yes. The evidence presented was sufficient to support a reasonable jury inference that the 'out-of round' condition of the brake drum caused the accident.
Analysis:
This case clarifies that the doctrine of strict liability does not eliminate the fundamental tort requirement of causation. While strict liability removes the plaintiff's need to prove the manufacturer was negligent, it does not remove the obligation to prove the defect actually caused the harm. This decision raises the evidentiary bar for plaintiffs in product liability cases where multiple potential causes for an accident exist. It requires plaintiffs to provide specific evidence, often through expert testimony, that causally links the defect to the injury as the most probable cause, thereby preventing juries from speculating among various possibilities.
