TortsProducts liabilityProximate causeIntervening and superseding causeForeseeabilitysuperseding causeintervening causesummary judgment
Facts
Plaintiffs brought a products liability action arising from injuries sustained after a spare tire assembly on a 1987 Ford van allegedly failed. The majority opinion states only that the case involved an alleged defect in the spare tire bracket assembly and a dispute over whether that defect was the proximate cause of plaintiff's injuries. The Court resolved the appeal by adopting the reasoning of the dissenting portion of the Appellate Division opinion. No further facts are set out in the Supreme Court's lead opinion itself.
Issue
Whether, in this products liability action, the evidence permitted a finding that the alleged defect in the spare tire bracket assembly was a proximate cause of plaintiff's injuries, or whether causation failed as a matter of law because of intervening, superseding conduct.
Rule
In a products liability case, proximate cause depends on whether the injury is sufficiently connected to the alleged defect under ordinary foreseeability principles; where reasonable minds could differ on that question, causation is for the jury rather than to be cut off as a matter of law by characterizing later conduct as superseding.
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10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Phoenix, a delivery van owned by Mateo Ruiz allegedly had a defective roof rack clamp manufactured by Desert Crest Equipment. While the van was parked along a curb, a ladder slid off onto the sidewalk. Seeing the ladder, Mateo sprinted into a busy intersection against the light to grab it and was hit by a motorcycle.
Desert Crest moves for summary judgment, arguing that Mateo's conduct was a superseding cause. What is the best response?
Explanation. The governing rule is that in a products liability case, proximate cause turns on ordinary foreseeability principles, and later conduct should not be labeled superseding as a matter of law if reasonable minds could differ about whether the injury remained sufficiently connected to the alleged defect. The majority held that causation could not be cut off as a matter of law on the record before it, so a court should deny summary judgment where foreseeability is debatable. (Derived from Yun v. Ford Motor Company (1996).)