Monday, March 25, 2013

MacPherson v. Buick Motor Company case brief

MacPherson v. Buick Motor Company case brief
217 N.Y. 382, 111 N.E. 1050 (1916)


SYNOPSIS:
Defendant car manufacturer appealed from a judgment of the Appellate Division of the Supreme Court in the Third Judicial Department (New York), which affirmed a judgment holding defendant liable for negligently failing to inspect a car that was bought by plaintiff car owner.

OVERVIEW: Defendant was an automobile manufacturer who obtained wheels for its automobiles from a separate manufacturer. Defendant sold its vehicles to automobile retailers. Plaintiff purchased one of defendant's vehicles from a dealer. Plaintiff was riding in the vehicle when it collapsed and plaintiff was injured. Plaintiff sued defendant for negligence. A jury verdict was rendered in plaintiff's favor.

HOLDING:
On appeal, the court affirmed, reasoning that defendant was not absolved from a duty of inspection on the ground that it bought the wheels from a reputable manufacturer.

ANALYSIS:
The court determined that because defendant was not merely a dealer in automobiles but was a manufacturer of automobiles, it was responsible for the finished product and was not at liberty to place the finished product on the market without subjecting the component parts to ordinary and simple tests.

RULES:
-If a manufacturer, who puts a finished product on the market to be used without inspection by his customers, is negligent, where danger is to be foreseen, a liability will follow.
-To make their negligence a cause of imminent danger, an independent cause must often intervene; the manufacturer of the finished product must also fail in his duty of inspection.
-It may be that in those circumstances the negligence of the earlier members of the series is too remote to constitute, as to the ultimate user, an actionable wrong.
-Where there is here no break in the chain of cause and effect, the presence of a known danger, attendant upon a known use, makes vigilance a duty.

OUTCOME: The judgment of the lower court was affirmed.

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