Prentis v. Yale Manufacturing Company

Michigan Court of Appeals · 1982 · Torts

323 N.W.2d 444 (1982)

Updated July 23, 2026

Products liabilityNegligenceBreach of warrantyJury instructionsStatutory interpretationimplied warrantydesign defectstandard jury instructions

Facts

Plaintiffs sought damages for injuries resulting from an accident involving an allegedly defective forklift manufactured by defendant Yale Manufacturing Company. The suit alleged both negligence and breach of warranty. The trial court refused to give requested standard jury instructions on breach of warranty because it concluded that Michigan's products liability statute had merged all prior products liability theories into a single unified products liability theory. The jury was therefore instructed only on negligence and returned a verdict finding that the product was not defectively designed by defendant.

Issue

Did Michigan's products liability statute abolish or merge the common-law implied warranty theory into a single negligence-based products liability theory, such that the trial court properly refused plaintiffs' requested implied-warranty jury instructions? If not, did the refusal to give those applicable standard jury instructions require reversal?

Rule

The products liability statute defines a products liability action broadly, but it does not require plaintiffs to proceed only under negligence or clearly abrogate the common-law implied warranty theory. Statutes will not be extended by implication to abrogate established common-law rules, and when an applicable and accurate standard jury instruction is properly requested but omitted, prejudicial error is presumed.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Grand Rapids, Lena Ortiz was injured when a commercial dough mixer allegedly lurched during normal use. She sued North Harbor Equipment, the manufacturer, alleging both negligent design and breach of implied warranty, and she properly requested standard implied-warranty jury instructions.

The trial judge concludes that Michigan's products liability statute created a single negligence-based products liability claim and therefore instructs the jury only on negligence. Which is the strongest argument on appeal?

Explanation. The majority held that Michigan's products liability statute did not merge negligence and implied warranty into a single negligence-only theory. Even though the statute broadly defines a products liability action, it does not clearly abrogate the common-law implied-warranty theory, and statutes are not extended by implication to abrogate established common law.