Monday, November 11, 2013

Daly v. General Motors Corp. case brief

Daly v. General Motors Corp. case brief summary
575 P.2d 1162 (Cal. 1978)

Plaintiffs appealed from a judgment for defendants in the Superior Court of Los Angeles County (California) in a products liability action.


Decedent, who was intoxicated and not wearing his seatbelt or using his door locks, died in a car crash after his door opened on impact and he was thrown from the car. Plaintiffs, decedent's family, sued defendants, the car manufacturer and distributor, in a products liability action for defective design of the door latch. The jury found for the defendants, and the trial court entered judgment accordingly.


  • On appeal, the court reversed because the trial judge committed prejudicial error when he allowed defendants to introduce evidence without a limiting instruction that decedent had been drunk and not using safety devices. 
  • The court also held that, in future, comparative negligence principles would apply to strict products liability actions.
  • Evidence of compensating design characteristics installed in a motor vehicle by its manufacturer to offset design deficiencies is admissible.


The court reversed the lower court's judgment because the trial court's admission of evidence, without a limiting instruction, that decedent was intoxicated and had failed to use safety equipment constituted prejudicial error.

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