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Rix v. General Motors Corp.

Supreme Court of Montana
723 P.2d 195 (1986)
ELI5:

Rule of Law:

In a strict products liability claim for a design defect, a plaintiff is not required to prove that the product reached the user without substantial change; instead, a jury must balance several factors to determine if a safer, feasible alternative design should have been used.


Facts:

  • General Motors Corporation (GMC) designed, manufactured, and sold a 1978 two-ton chassis-cab.
  • The chassis-cab was equipped with a single brake system as standard, though GMC had the capability to install a dual brake system, which it offered as optional equipment.
  • After being sold by a GMC dealer, the chassis-cab was equipped with a water tank by a third party.
  • On August 4, 1978, John Stanley Fisher was driving the GMC truck when its brakes failed due to a hydraulic fluid leak from a brake line.
  • As a result of the brake failure, the truck collided with the rear of a pickup truck operated by Michael Rix.
  • Michael Rix was injured in the collision.

Procedural Posture:

  • Michael Rix sued General Motors Corporation in the Yellowstone County District Court, which is the state's trial court.
  • The lawsuit was based on a theory of strict products liability.
  • The case was tried before a jury.
  • The jury returned a verdict in favor of the defendant, GMC.
  • The plaintiff, Michael Rix, as appellant, appealed the judgment to the Supreme Court of Montana.

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Issue:

In a strict products liability action based on a design defect, does a jury instruction requiring the plaintiff to prove the product reached the consumer without substantial change in condition misstate the law?


Opinions:

Majority - Mr. Justice Weber

Yes. In a strict products liability action based on a design defect, a jury instruction requiring the plaintiff to prove the product reached the consumer without substantial change misstates the law. The court reasoned that there is a critical distinction between manufacturing defect claims and design defect claims. For a manufacturing defect, where the product deviates from its intended design, the 'no substantial change' requirement is appropriate. However, for a design defect claim, the focus is on the inherent safety of the design itself, which does not change after manufacture. Citing 'Kuiper v. Goodyear Tire & Rubber Co.', the court held that changes to the product through wear, tear, or modification do not affect the question of whether the original design was defective. The court therefore adopted a multi-factor balancing test for juries to apply in cases alleging a design defect where a feasible alternative design existed.



Analysis:

This decision clarifies the distinction between manufacturing and design defect theories in Montana's strict products liability jurisprudence. By eliminating the 'no substantial change' requirement for design defect claims, the court significantly eased the plaintiff's burden of proof in such cases. The most important impact is the adoption of a new, five-factor risk-utility balancing test for design defect cases involving feasible alternatives. This moves Montana law toward a more nuanced analysis that requires juries to weigh the costs, benefits, and feasibility of safer designs, setting a clear precedent for future product liability litigation in the state.

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