Donald C. MacPherson v. Buick Motor Company Case Brief

Summary of Donald C. MacPherson v. Buick Motor Company, 217 N.Y. 382; 111 N.E. 1050, Court of Appeals of New York [1916]

Facts: Defendant was a manufacturer of automobiles which bought its wheels from a separate manufacturer. Defendant sold automobiles to a retailer, which sold the vehicle [in this case] to plaintiff MacPherson. Plaintiff was in the vehicle when it suddenly collapsed, because a spoke shattered which was manufactured with defective wood. Plaintiff was thrown from the car and injured. It was found that the defect in the wheel, had it been inspected, could easily have been discovered. However, defendant did not inspect the wheel before selling the automobile to the retailer.

Plaintiff sued for damages, stating that defendant was negligent in not inspecting the wheels on the automobile. Defendant claimed there was no duty of care to anyone but the immediate purchaser.

History: The trial court found for plaintiff. Defendant appealed to the Appellate Division of the Supreme Court in the Third Judicial Department (New York), where the judgment was affirmed. Defendant appealed to this court.

Issue: Did defendant owe a duty of care and vigilance to plaintiff?

Ruling: Yes. The Court of Appeals of New York affirmed the judgment of the lower court.

Rule/Analysis: Defendant argued that only those items whose normal function is to injure or destroy [such as poisons, explosives, etc.] are considered imminently dangerous and therefore no duty was owed to plaintiff. However, the court found that if a manufacturer is supplying goods in which a danger may be foreseen if its construction is defective, there is a cause for negligence. In this case, it was apparent that an automobile is a good which fits this description. It could be foreseen that if the wheels are defective, and an automobile is traveling at fifty miles an hour, an injury would almost be certain.

The remoteness of the relationship between defendant and plaintiff was also a factor considered by the court. Defendant claimed to owe a duty of care only to the retailer. It should have been apparent to defendant, however, that an automobile retailer, by nature of its business, would not use the vehicle and would resell it to the general public. Therefore, the court felt that it could be reasonably foreseen by defendant that plaintiff would be injured by a defect in the wheels and therefore a duty of care was owed.

Summary: Defendant was negligent in the fact that it did not inspect the wheels prior to selling the vehicle for resale to the public. Defendant owed a duty of care to plaintiff. Judgment was affirmed in plaintiff’s favor.

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