Greenman v Yuba Power Products
[1963]
Author:- Sam Biers

Relevant Facts: Pl Greenman purchased a combination power tool that could be used as a saw, drill, and wood lathe.  He saw it demonstrated and read the brochure prepared by the manufacturer.  He subsequently purchased the necessary attachments to use the Shopsmith as a lathe.  After he had worked on the piece of wood several times it flew out of the machine and struck him in the forehead, inflicting serious injuries.  10 mos later he gave the retailer and manufacturer written notice of claimed breaches of warranties and filed a complaint. Expert testified that inadequate set screws were used to hold parts of the machine together, and there were other positive ways of fastening the parts which would have prevented the accident.

Legal Issue(s): Whether the manufacturer is strictly liable for the injury complained of by Pl as a result of a defect in the Shopsmith?

Court’s Holding: Yes

Procedure: Jury trial returned a verdict for pl against manufacturer only;

Law or Rule(s): A manufacturer is strictly liable in tort when an article he places on the market, knowing that it is to be used w/o inspection for defects, proves to have a defect that causes an injury to a human being.

Court Rationale: Rules defining and governing warranties that were developed to meet the needs of commercial transactions cannot properly be invoked to govern the manufacturer’s liability to those injured by their defective products unless those rules also serve the purposes for which such liability is imposed. The purpose of such liability is to insure that the costs of injuries resulting from defective products are borne by the manufacturer that put such products on the market rather than by the injured persons who are powerless to protect themselves.  Implicit in the machine’s presence on the market was a representation that it would safely do the jobs for which it was built.  It should not be controlling whether the pl selected the machine b/c of the statements in the brochure, or b/c of the machine’s own appearance of excellence that belied the defect lurking beneath the surface.

To establish the manufacturer’s liability it was sufficient that PL proved that he was injured while using the Shopsmith in a way in which it was intended to be used as a result of a defect in design and manufacture of which PL was not aware that made the Shopsmith unsafe for its intended use.

Plaintiff’s Argument: The Shopsmith was not safe for its intended use, and had a design defect which caused an injury to the Pl.

Defendant’s Argument: Pl did not give df notice of breach w/i a reasonable time and his claim is barred by law.