Ford Motor Co. v. Matthews

Brief Fact Summary. Earnest Matthews (Mr. Mathews) was dragged under a tractor and killed when he started the tractor while standing next to it. The tractor started while in gear, but was equipped with a safety switch designed to prevent this from occurring.

Synopsis of Rule of Law. A manufacturer is not liable for injuries caused by abnormal or unintended use of its product, only if such use is not reasonably foreseeable.

Facts. Mr. Matthews was standing beside his tractor when he started it and the tractor was in gear at the time. The tractor, manufactured by the Appellant, Ford Motor Company (Appellant), was equipped with a starter safety switch designed to prevent the tractor from being started while in gear. When the tractor started, Mr. Matthews was dragged underneath a disc attachment, killing him. The Appellee, the administratrix (Appellee) brought suit, claiming that the plunger connected with the safety switch was defective, allowing the tractor to be started in gear. The trial court found for the Appellee and Appellant appealed.

Issue. Was Mr. Matthews’ act of standing on the ground and starting the tractor a misuse of the product so as to be an absolute limitation on Appellant’s liability?

Held. No. Judgment affirmed.
* Appellant relies on the Restatement [Restatement (Second) of Torts Section: 402A], which states in part that a seller is not liable for injury that results from abnormal handling. Several cases are also cited by Appellant, but in each case the accident was caused by misuse, with the court finding either no defect or that the defect played no part in the accident.
* The injury in question was not caused by Mr. Matthews negligently standing beside the tractor when he started it. Rather, if any negligence occurred on Mr. Matthews’ part, it was not checking to make sure the tractor was in gear. In the present case, even if Mr. Matthews were guilty of negligence for this failure, the negligence was foreseeable by Appellant and this is not a bar to an action based on strict liability for a manufacturing defect.

Discussion. If the deceased had used the tractor in an unforeseeable and abnormal way, the manufacturer would not be subject to liability. In this case, the Court found that not checking to make sure the tractor was not in gear was foreseeable.