Prentis v. Yale Mfg Co. case brief
Facts: Prentis, a foreman of parts department at a dealership, sustained a hip injury in an accident that involved a forklift made by Yale and sold to Prentis’s employer in 1952. The forklift was a standup or walking type instead of a riding or sit down type. It had a dead-man switch which normally prevented it from moving if operator let go of handle or controls. Accident occurred late in the day when the battery was getting low; Prentis tried to start the machine up by working handle and machine had a power surge; he lost his footing and fell to the ground. Injuries seem to be only from the fall. Prentis tried to prove that because the machine was not a sit-down model and did not incorporate a “human factor” into functioning, it was defective in design.
Reasoning: Those injured by defective products should be compensated for their injuries without beginning subject to contractual intricacies of the law of sales; and since manufacturers can most effectively distribute the costs of injuries. However, the plaintiff has to prove that the product is actually dangerous and something is wrong that makes it dangerous. The plaintiff must show that the product was defective all the time. However, it’s a little tough with the design of a product; it can work but there is no one test.
There are four approaches for determining a defect in design. 1. Employ a negligence risk-utility analysis which focuses on manufacturer being judged negligent if it knew that product was dangerous 2. Compare the risk and utility of the product at trial 3. Consumer expectations about product 4. Combine risk-utility with consumer expectation. Some form of risk-utility is the most often used analysis.
The court basically said underlying reasoning is negligence and employs judge hand’s formula from Carroll towing case. They look at product instead of the manufacturer’s conduct. Generally, jury instructions focus on whether the manufacturer exercised reasonable care in making their design choices. So the court decided to adopt a negligence standard and explanation to products liability because it is more fair and easier to explain. The formula requires documentation obtained through discovery, whether plaintiff was somehow at fault and contributed to it, that a safer design could have been available, and that design case will be against the entire line so it requires more stringent rules.
Negligence standard only defines in clear guidelines on how to decide a case and what to think about. Pure negligence, risk-utility test is just like negligence and will go far in helping jurors understand. The only thing to be considered in product liability action based on defective design is a single unified theory of negligent design and whether the manufacturer used reasonable care in designing a product.
Holding: In products liability action against a manufacturer for an alleged defect in the design of its product, where the jury was properly instructed on the theory of negligent design, trial judge’s refusal to instruct on breach of warranty is not reversible error.