Rix v. General Motors Corp.

Supreme Court of Montana · Torts

TortsProducts liabilityStrict liabilityDesign defectManufacturing defectEvidencestrict liabilityproducts liability

Facts

Rix was injured when his pickup was struck from behind by a 1978 GMC two-ton chassis-cab equipped with a water tank after sale by a GMC dealer. The parties stipulated that failure of a brake line carrying hydraulic fluid caused the brake failure, and that the truck had a single brake system even though GMC had the knowledge and capability to incorporate a dual system and offered it as optional equipment. Rix claimed both a manufacturing defect in the brake tube and a design defect in the use of a single brake system. GMC agreed the tube was defective but argued it had been altered after leaving the assembly line, and also argued the single brake system was not defectively designed or unreasonably dangerous.

Issue

Whether the trial court properly instructed the jury on strict liability where the plaintiff advanced both manufacturing-defect and design-defect theories, and whether the other challenged evidentiary and discovery rulings required reversal. More specifically, the central question was whether instructions requiring the product to reach the consumer without substantial change misstated Montana law as to design defect.

Rule

In a strict-liability manufacturing-defect case, Restatement (Second) of Torts § 402A applies, and the plaintiff may be required to show the product reached the user without substantial change. In a strict-liability design-defect case, the focus is whether the manufacturer improperly designed the product it placed in the stream of commerce; the plaintiff need not prove the product reached the consumer without substantial change in condition. In an alternative-design case, the jury should balance pertinent factors at the time of manufacture, including: the reasonable probability the original design would cause serious harm, the comparative probability of harm from the original and alternative designs, the technological feasibility of the alternative design, the relative costs of the original and alternative designs to manufacturer and consumer, and the time reasonably required to implement the alternative design. Rule 407 applies to strict liability actions under both manufacturing and design defect theories, so subsequent design changes are generally inadmissible except for other purposes such as feasibility or impeachment when genuinely controverted.

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

In Helena, Montana, Nora Vega was injured when a delivery van rolled backward after its transmission parking mechanism failed. She sued Ironcrest Vehicles, alleging both that one gear component was mis-machined and that the van was defectively designed because the manufacturer sold it with a single locking pawl even though a dual-locking system was technologically feasible and offered as optional equipment at the time of manufacture.

At trial, the judge gives one global strict-liability instruction requiring Nora to prove the van "reached the user without substantial change in condition" for all theories. If Nora appeals, what is the best argument?

Explanation. The majority distinguishes manufacturing and design defects. For manufacturing defect, § 402A-style instructions may require proof that the product reached the user without substantial change. But for design defect, the focus is whether the manufacturer improperly designed the product it placed in the stream of commerce; the plaintiff need not prove no substantial change in condition after sale. A single instruction imposing that requirement on both theories is reversible error when applied to design defect. (Derived from Rix v. General Motors Corp. (n.d.).)