Rix v. General Motors Corp

Brief Fact Summary. Plaintiff was injured when the truck he was driving was rear-ended by a 1978 GMC two-ton chasis-cab. Plaintiff brought suit against General Motors Corp. (Defendant) on a theory of strict liability, as the manufacturer of the truck.

Synopsis of Rule of Law. A manufacturer cannot be held strictly liable for the danger caused by one of its products, if it does not cause the defect in the product.

Facts. Plaintiff was injured when his pickup was hit from behind by a chasis-cab that had been equipped with a water tank, after sale, by the Defendant dealership. Plaintiff brought suit against Defendant under a theory of strict liability, and products liability, maintaining that the product, which had been placed into the stream of commerce, was unreasonably dangerous because of both manufacturing and design defects. At the trial in this matter, the jury reached a verdict for Defendant, and Plaintiff appealed.

Issue. Whether strict liability is a proper manufacturing defect theory?

Held. Reversed and remanded.
* While this case was reversed and remanded, the court held, in line with the jury instructions, that a manufacturer could not be held to strict liability for manufacturing defect, when the product was not defective when it left the manufacturer’s assembly line. In this case, the truck was not altered by the manufacturer, but by the dealer after sale. Thus, the manufacturer could not be held strictly liable for a defect that was not caused at its hands.

Discussion. This case goes into the theory of strict liability, in the context of products liability.
* As a rule, when a manufacturer sends a product into commerce, he will be held liable for any harm caused to the ultimate user or consumer.
* This rule does not apply, if the product is altered after it leaves the care of the manufacturer, and it is fundamentally unfair to hold a manufacturer liable on those grounds.