General Motors Corporation v. Sanchez

Brief Fact Summary.

After Sanchez’s (Plaintiff) estate successfully sued General Motors Corporation (Defendant) after Plaintiff was crushed by his pickup truck, Defendant appealed, arguing that the court should have applied the comparative responsibility statute.

Synopsis of Rule of Law.

While a product consumer is not responsible for discovering or guarding against a product defect, that consumer’s negligent conduct could allow for a reduction in damages for comparative responsibility even in strict liability cases.

Facts.

Plaintiff left his pickup truck running while he opened a gate and the truck rolled backwards, crushing and killing him. Plaintiff’s estate sued Defendant, alleging a defective transmission design, negligence, and failure to provide appropriate warnings. The jury found for Plaintiff on each of these claims, but also found Plaintiff to be fifty percent responsible for the accident. The trial court awarded the estate $8.5 million in actual and punitive damages. Defendant appealed, arguing that the court should have applied the comparative responsibility statute.

Issue.

Will a product consumer’s negligent conduct in strict liability cases allow for a reduction in damages for comparative responsibility?

Held.

(Gonzales, J.) Yes. While a product consumer is not responsible for discovering or guarding against a product defect, that consumer’s negligent conduct could allow for a reduction in damages for comparative responsibility even in strict liability cases. The design defect finding creates strict liability for Defendant. Under the comparative responsibility statute, a court reduces the plaintiff’s damages by the percentage of responsibility attributed to his own negligence. Plaintiff’s conduct before the accident went beyond not discovering or protecting himself against a product defect. The jury determined that Plaintiff did not use ordinary care and that he was fifty percent responsible for the accident. The punitive damages award is reversed because there is no evidence of Defendant’s gross negligence and the actual damages award is reduced by fifty percent due to Plaintiff’s comparative responsibility.

Discussion.

In 1987, the Texas statute was revised to replace comparative negligence with comparative responsibility. Here, the court found that a consumer using ordinary care would know enough to take precautions to prevent a car from rolling back.