Winnett v. Winnett
57 Ill. 2d 7, 310 N.E.2d 1, 1974 Ill. LEXIS 356 (1974)
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Rule of Law:
In a strict products liability action, a manufacturer's duty extends only to those injuries that are objectively reasonable to expect, not to every injury that might conceivably occur. The determination of whether an injury was objectively foreseeable can be a question of law for the court.
Facts:
- Helix Corporation manufactured a forage wagon.
- The wagon featured two exposed, slow-moving conveyor belts with holes large enough to admit the fingers of a small child.
- The conveyor belts were not equipped with any shield, guard, or protective device, nor were there provisions for attaching one.
- Four-year-old Teresa Kay Winnett was visiting her grandfather's farm where he was operating the forage wagon.
- Teresa was attracted to the moving belts and the pieces of vegetation on them.
- She approached the operating wagon and placed her fingers on or in one of the moving conveyor belts.
- Her fingers were pulled into the mechanism beneath the steel end of the wagon, causing injury.
Procedural Posture:
- Teresa Kay Winnett sued Helix Corporation in the circuit court of Coles County (trial court), alleging strict tort liability in count II of her complaint.
- Helix Corporation filed a motion to dismiss count II for failure to state a cause of action.
- The trial court granted the motion and dismissed the strict liability claim against Helix Corporation.
- Winnett, as appellant, appealed the dismissal to the Appellate Court for the Fourth District.
- The Appellate Court reversed the trial court's judgment, holding that the complaint did state a valid cause of action.
- Helix Corporation, as appellant, was granted leave to appeal to the Supreme Court of Illinois.
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Issue:
Does a manufacturer's duty in strict tort liability extend to a four-year-old bystander injured by an exposed mechanism on a forage wagon, where the circumstances of the injury were not objectively reasonably foreseeable?
Opinions:
Majority - Mr. Chief Justice Underwood
No. A manufacturer's liability in strict tort does not extend to this situation because the injury was not objectively reasonably foreseeable. While strict liability protects users, consumers, and foreseeable bystanders, this protection is not limitless. The liability of a manufacturer properly encompasses only those individuals to whom injury from a defective product may reasonably be foreseen and only in situations where the product is being used for an intended or reasonably foreseeable purpose. The court determined that it is not objectively reasonable for a manufacturer to expect that a four-year-old child will be permitted to approach and touch an operating piece of farm machinery. Therefore, even though the injury was conceivable, it fell outside the scope of foreseeable risk for which a manufacturer should be held strictly liable.
Dissenting - Mr. Justice Goldenhersh
Yes. The manufacturer's duty should extend to the plaintiff in this case. The complaint sufficiently alleged all the necessary elements for a strict liability claim under existing precedent: the product was unreasonably dangerous, this condition existed when it left the manufacturer's control, and the condition proximately caused the plaintiff's injury. The majority errs by deciding the issue of foreseeability as a matter of law. Whether it was reasonably foreseeable that someone might be injured by coming into contact with the unguarded, dangerous mechanism is a question of fact that should be resolved by a jury, not dismissed by a court.
Analysis:
This decision significantly refines the scope of strict products liability in Illinois by solidifying foreseeability as a key limiting principle, even in cases involving bystanders. It establishes that foreseeability is not merely about whether a product is dangerous, but whether the specific circumstances of the injury were 'objectively reasonable to expect.' By treating this determination as a question of law that a court can decide, the ruling creates a judicial gatekeeping function that can prevent certain strict liability cases from reaching a jury, thereby protecting manufacturers from liability for injuries deemed too remote or unusual.
