Wednesday, January 1, 2014

Stahlecker v. Ford Motor Company case brief

Stahlecker v. Ford Motor Company case brief summary
667 N.W.2d 244 (2003)

Appellant parents sought damages from appellees, a car manufacturer and a tire manufacturer, resulting from the injury and wrongful death of their daughter. Their daughter's vehicle experienced tire failure in a remote area and the daughter was subsequently raped and murdered. The District Court for Dodge County (Nebraska) sustained demurrers filed on behalf of the manufacturers and dismissed the action as to those parties. The parents appealed.

The parents alleged that as the "direct and proximate result" of the negligence of the manufacturers, their daughter's car was rendered unusable, leaving her in a foreseeably dangerous situation, which ultimately led to her murder. The parents alleged the existence of a legal duty and a breach thereof.

The issue was, whether the criminal assault and murder were the "natural and probable" result of the failure to warn of potential tire failure, or did the criminal acts constitute an effective intervening cause precluding any causal link between the failure to warn and the wrongful death for which damages were claimed?

  • The supreme court held that although the petition alleged sufficient facts to establish that the manufacturers negligently placed defective products on the market which caused the decedent to become stranded at night in a remote location, it alleged no facts upon which either manufacturer would have had a legal duty to anticipate and guard against the criminal acts which were committed at that location by another party. 
  • Therefore, the criminal acts constituted an efficient intervening cause which defeated proof of the essential element of proximate cause.
The judgment of the trial court was affirmed.

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