MacPherson v. Buick Motor Co.

Brief Fact Summary.

MacPherson (Plaintiff) sued Buick Motor Co. (Defendant) for negligence when the car Defendant manufactured broke and injured Plaintiff.

Synopsis of Rule of Law.

A manufacturer has a duty of care to third party purchasers when the manufacturer knows the thing of danger it manufactures will be used by someone other than the initial purchaser without further testing.

Facts.

MacPherson (Plaintiff) purchased from a retail dealer a car that was manufactured by Buick Motor Co. (Defendant). One of the wheels, which Defendant had purchased from another manufacturer, was defective. The evidence presented in the case showed that the defect could have been discovered if Defendant had completed a reasonable inspection. The wheel crumbled and Plaintiff was thrown from the vehicle, sustaining injuries.

Issue.

Does Defendant owe a duty of care to a third party purchaser?

Held.

Yes, the Court held Defendant did owe a duty of care to a third party purchaser.

Dissent.

Justice C.J. Bartlett

The dissent believed the majority extended manufacturer liability too far by expanding it to third party purchasers. The precedent cited by the dissent only recognized liability in cases where the ordinary use of the object led to danger.

Discussion.

The Court found that a manufacturer has a duty of care to third party purchasers when the manufacturer knows the thing of danger will be used by someone other than the initial purchaser without further testing. In this case, a car is a thing of danger because there is more than a probable risk to human life if the car is negligently made. Defendant knew that someone other than the initial purchaser would use the car because the purchaser was a car dealer and the car had three seats. The Court said Defendant was responsible for the final product it put out, even if the manufacturer of the wheels was the one who created the faulty part.