Cruz v. DaimlerChrysler Motors Corp.

Brief Fact Summary.

Plaintiff was injured when the airbags in his car suddenly deployed. He sued both the manufacturer and the dealership for negligence.

Synopsis of Rule of Law.

Res ipsa loquitor applies where: (1) the event that occurred does not ordinarily occur in the absence of negligence, (2) other responsible causes of the plaintiff’s harm are sufficiently eliminated, and (3) the negligent act was within the scope of the defendant’s duty to the plaintiff.

Facts.

Cruz was cleaning the inside of his minivan when the airbags suddenly deployed and injured him. He had purchased the used minivan three years earlier from Ricky Smith’s dealership. Cruz filed suit for negligence and negligent misrepresentation against both Smith and the car’s manufacturer, DaimlerChrysler Motors Corp. Cruz voluntarily dismissed his lawsuit against Daimler Chrysler Motors Corp. after the company filed for bankruptcy. Smith was left as the sole defendant in the case. Cruz amended his complaint to seek recovery against Smith based on the doctrine of res ipsa loquitor. At trial, Cruz produced no direct evidence linking the spontaneous deployment of the airbags to any negligent conduct on behalf of Smith. The trial court granted summary judgment for Smith. Cruz appealed to the Supreme Court of Rhode Island.

Issue.

Whether a person is liable for negligence under the doctrine of res ipsa loquitor when there are other possible causes of plaintiff’s injury?

Held.

No, all three elements must be met to satisfy the doctrine of res ipsa loquitur. The three elements are (1) the event that occurred does not ordinarily occur in the absence of negligence, (2) other responsible causes of the plaintiff’s harm are sufficiently eliminated, and (3) the negligent act was within the scope of the defendant’s duty to the plaintiff. Cruz cannot avail himself to the doctrine of res ipsa loquitor when three years had passed since Smith sold him the minivan. The evidence Cruz produced at trial did not sufficiently eliminate other responsible causes. The trial court’s grant of summary judgment for defendant on the negligence and negligent misrepresentation claims is affirmed.

Discussion.

Under res ipsa loquitor, inferential evidence can be used to satisfy a claim for negligence. In a previous case, the court adopted the view of the Restatement (Second) of Torts by holding that res ipsa loquitor applies where: (1) the event that occurred does not ordinarily occur in the absence of negligence, (2) other responsible causes of the plaintiff’s harm are sufficiently eliminated, and (3) the negligent act was within the scope of the defendant’s duty to the plaintiff. Here, the court admits that the spontaneous deployment of airbags ordinarily does not occur in the absence of negligence. However, three years had passed since Cruz’s purchase of the minivan. If the airbags had spontaneously deployed shortly after his purchase, then an inference of negligence could have been permitted because the minivan may have been defective when sold. However, too much time had passed for the accident to be within Smith’s scope of duty. Additionally, other potential causes of the airbag deployment had not been sufficiently eliminated by the evidence. Therefore, the trial court properly granted summary judgment to Smith on Cruz’s negligence claim.