Greenman v. Yuba Power Products
Citation: 59 Cal. 2d 57 (1963)
Facts
Greenman was injured when a piece of wood flew out of a combination power tool (Shopsmith) manufactured by Yuba Power Products. He sued in negligence and warranty. The trial court dismissed the warranty claim but found for Greenman on negligence grounds.
Issue
Should a manufacturer be strictly liable in tort for injuries caused by a defective product placed on the market?
Holding
Yes. A manufacturer is strictly liable in tort when it places on the market a product with a manufacturing defect that causes injury to a person who uses it in a reasonably foreseeable manner. Strict liability eliminates the need to prove negligence and overcomes the problems with warranty liability.
Rule
Strict products liability: A manufacturer is strictly liable when an article it places on the market proves to have a defect that causes injury to a human being. The plaintiff need not prove negligence — only that the product was defective when it left the manufacturer’s hands and that the defect caused the injury.
Significance
- Justice Traynor’s opinion established the doctrine of strict products liability in California — the first clear statement of the rule
- Basis for the Restatement (Second) of Torts § 402A (adopted by most states)
- Eliminated the privity and notice requirements of warranty law
- Product liability now encompasses manufacturing defects, design defects, and failure-to-warn defects