Monday, January 6, 2014

Peterson v. Superior Court of Riverside County case brief

Peterson v. Superior Court of Riverside County case brief summary
10 Cal. 4th 1185 (1995)

CASE SYNOPSIS
Defendant hotel owner appealed an order of the Superior Court of Riverside County (California), which reversed the trial court's order granting defendant's motion in limine and which permitted plaintiff hotel guest to introduce evidence of strict products liability in her action against defendant for injuries sustained while using a bathtub in defendant's hotel.

CASE FACTS
Plaintiff hotel guest filed an action for negligence and strict product liability against defendant hotel owner for injuries sustained when she slipped in the hotel bathtub.

PROCEDURAL HISTORY
The trial court granted defendant's motion in limine to preclude plaintiff from introducing evidence of strict liability, holding that defendant could not be strictly liable as a matter of law. The court of appeals issued an opinion holding that a peremptory writ of mandate should issue directing the trial court to permit plaintiff to proceed on her strict liability theory concluding that Becker v. IRM Corp., 38 Cal. 3d 454 (1985) applied to hotel proprietors. Defendants sought review and the court reversed the court of appeals judgment.

DISCUSSION

  • The court overruled that portion of its decision in Becker imposing strict products liability, and held that neither landlords nor hotel proprietors were strictly liable on a products liability theory for injuries to tenants and/or guests caused by a defect in the premises. 
  • The court held that it erred in applying the doctrine of strict products liability to a residential landlord that was not part of the manufacturing or marketing enterprise of an allegedly defective product.

CONCLUSION
The court reversed the court of appeals judgment, holding that plaintiff hotel guest could not proceed against defendant hotel owner on a strict products liability theory for injuries sustained while using a hotel bathtub because neither landlords nor hotel proprietors were strictly liable on a products liability theory for injuries to tenants and/or guests caused by a defect in the premises.

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