Elmore v. American Motors Corp.
Citation and Court
70 Cal. 2d 578 (1969), Supreme Court of California
Facts
A defective drive shaft in an American Motors vehicle broke loose during operation, causing the car to veer across the center line and collide with an oncoming vehicle. The plaintiff in the oncoming vehicle was not the purchaser of the defective car and had no contractual relationship with the manufacturer. Elmore sued American Motors under strict products liability as a bystander injured by the defective product.
Issue
Whether strict products liability extends to bystanders who are injured by a defective product but who have no direct relationship with the manufacturer or seller.
Holding
The court held that strict products liability extends to bystanders injured by defective products, not just to purchasers or users of the product.
Rule / Doctrine
The policy rationale for strict liability — placing the cost of defective products on manufacturers who profit from their sale and are best positioned to prevent defects — applies with at least equal force to innocent bystanders as to purchasers and users. Privity and contractual relationship are not prerequisites for strict products liability recovery.
Significance
Elmore is a landmark case extending strict liability beyond the buyer-seller relationship to cover injured bystanders. It reflects the California Supreme Court’s broad conception of strict liability and has been influential in jurisdictions that extend products liability protection to all foreseeable victims of defective products.