Brief Fact Summary. Young (Plaintiff) was killed in an automobile manufactured by Volkswagen of America, Inc., (Defendant) because of a negligent driver who rear-ended him. There was a defect in a safety device that attributed to Plaintiff’s death.
Synopsis of Rule of Law. One injured in an automobile accident has an action against the vehicle’s manufacturer if his injuries were the result of the manufacturer’s negligent defective design of the automobile.
The general rule, to which we adhere, is that the law of the place of the sale determines the extent and effect of the warranties which attend the sale.View Full Point of Law
Issue. Is Defendant, an automobile manufacturer, liable when Plaintiff suffers injuries in an accident due to a defective safety design?
Held. Yes. Judgment for Plaintiff.
* The fact that the design does not cause the initial collision should make no difference if it is the cause of the ultimate injury. When the injuries to an occupant of a motor vehicle resulted from both the negligence of a driver as well as a negligent condition created by some other entity, the court has held that both negligent actors may be liable.
* While the intended purpose of an automobile may not be to participate in collisions, the intended purpose includes providing a reasonable measure of safety when, inevitably, collisions do occur. Automobiles are now equipped with additional safety devices such as seatbelts, shoulder harnesses, padded dashboards, etc. Frequent collisions are foreseeable, and the intended purpose of all of these parts of the vehicle is to afford reasonable safety when those collisions occur.
Discussion. This case holds Defendant liable for their product when the initial cause of the accident was not Defendant’s fault. It is foreseeable and predictable that an automobile will be involved in an accident. Plaintiff expected the seat and seatbelt to help protect him in the event he was to get in an accident. The safety devices malfunctioned and Plaintiff was killed as a result. Defendant is liable to Plaintiff under a theory of strict products liability.