Williams v. RCA Corp.
59 Ill. App. 3d 229, 376 N.E.2d 37, 17 Ill. Dec. 144 (1978)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
In a strict products liability claim, an intervening criminal act is a superseding cause that breaks the chain of proximate causation if the criminal act was not an objectively foreseeable consequence of the product's failure, particularly where the product was not designed or intended to prevent such criminal acts.
Facts:
- Plaintiff worked as a security guard for an investigative service.
- His employer provided him with a two-way portable receiver manufactured by defendant, RCA Corporation.
- While on duty watching a restaurant, a robbery occurred.
- Plaintiff used the receiver, per his employer's instructions, to call for backup from patrols in the area.
- Unknown to the plaintiff, the receiver was defective and failed to transmit his request for assistance.
- Believing assistance was on its way or otherwise proceeding with his duties, plaintiff attempted to apprehend the robber alone.
- During the attempted apprehension, the robber shot and wounded the plaintiff.
Procedural Posture:
- Plaintiff filed a complaint in a state trial court against RCA Corporation (defendant) based on a theory of strict tort liability.
- Defendant filed a motion to dismiss the complaint for failure to state a cause of action, arguing it had no duty and the criminal act was an unforeseeable, intervening cause.
- The trial court granted the defendant's motion to dismiss.
- Plaintiff, as appellant, appealed the trial court's order of dismissal to the intermediate appellate court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is an intervening criminal act a superseding cause that absolves a manufacturer of strict liability for a defective product when the act was not objectively foreseeable and the product was not designed to prevent criminal attacks?
Opinions:
Majority - Mr. Presiding Justice Sullivan
Yes. An intervening criminal act breaks the causal connection between a defective product and an injury, relieving the manufacturer of liability, if the criminal act was not an objectively reasonable event for the manufacturer to expect. The court determined that foreseeability means that which is objectively reasonable to expect, not what might conceivably occur. The court distinguished this case from others where liability was found because the product here, a two-way receiver, was designed for communication, not for the prevention of criminal attacks. Therefore, the manufacturer could not be reasonably expected to foresee that a product failure would lead to a user being shot by a third-party criminal. The court concluded that while the shooting was conceivable in retrospect, it was not an objectively foreseeable consequence of the receiver's malfunction.
Analysis:
This decision refines the concept of proximate cause in Illinois products liability law by emphasizing the product's intended purpose in the foreseeability analysis for intervening criminal acts. It establishes that for manufacturers of general-purpose products, a criminal act will likely be deemed a superseding cause, breaking the chain of liability. The ruling effectively creates a higher bar for plaintiffs to prove foreseeability in such cases, distinguishing between products designed for communication and those specifically designed for crime prevention. This narrows the scope of manufacturer liability and allows courts to dismiss claims as a matter of law where the link between the product defect and the criminal act is considered too remote or not 'objectively reasonable to expect.'
