Greenman v. Yuba Power Products, Inc.

Brief Fact Summary.

Greenman (Plaintiff) was injured by a piece of wood flying out of the power tool manufactured by Yuba Power Products, Inc. (Defendant).

Synopsis of Rule of Law.

1. A plaintiff who is injured is not beholden to a strict time limit for reporting breach of warranties to the manufacturer.
2. Plaintiffs do not need to demonstrate breach of express warranty or implied warranty because manufacturers are responsible for their products under a strict liability standard.

Facts.

Greenman (Plaintiff) received a power tool made my Yuba Power Products, Inc. (Defendant) as a present. He used it many times without issue. One day while using the tool as a lathe to turn wood, the wood flew out of the tool and hit Plaintiff in the head. Plaintiff notified Defendant 10.5 months later. Plaintiff’s expert witnesses testified that Plaintiff’s injuries were caused by improper manufacturing of the power tool.

Issue.

1. Is Plaintiff’s claim on breach of warranties limited by the extended amount of time Plaintiff took to notify Defendant?
2. Is Defendant liable even if Plaintiff cannot show a breach of express warranty or implied warranty?

Held.

1. No, the Court held Plaintiff’s claim is not limited by the amount of time it took to notify Defendant.
2. Yes, the Court held Defendant is liable even if Plaintiff does not show a breach of express warranty or implied warranty.

Discussion.

The Court found that the requirement of notification of a breach of warranties within a reasonable period of time did not extend to the relationship between Plaintiff and Defendant, the manufacturer. There was no previous relationship between the two, and Plaintiff was not experienced in these practices.

The Court also found it to be unnecessary for Plaintiff to show a breach of either express warranty or implied warranty. Manufacturers are liable under a strict liability standard for any defect that causes an injury to a plaintiff while plaintiff is using the product in the intended manner.