MacPherson v. Buick Motor Co.

Summary

The New York Court of Appeals holds that an automobile manufacturer may owe a duty of reasonable care to persons other than the immediate purchaser when the product is reasonably certain to endanger life or limb if negligently made. The court concludes that Buick had a duty to inspect the automobile's component parts, even though the defective wheel was manufactured by another company. The judgment for the injured plaintiff was affirmed.

Holdings

1. A manufacturer of a finished product owes a duty, independent of contract, to persons other than the immediate purchaser when the product is reasonably certain to endanger life or limb if negligently made, the manufacturer knows it will be used by others without new tests or inspection, and the danger is probable rather than merely possible.
2. A manufacturer of a finished automobile is not absolved from its duty of inspection merely because it purchased a component part from a reputable supplier; it is responsible for the finished product and must subject component parts to ordinary and simple tests reasonably required by the nature of the product and the danger.
3. Any possible error in the trial court's characterization of the automobile as not inherently dangerous was not reversible because the charge nevertheless submitted whether the automobile would become imminently dangerous if negligently constructed and whether Buick should have foreseen the danger.

Questions Presented

1. Whether an automobile manufacturer owes a duty of reasonable care to persons other than the immediate purchaser when the automobile is likely to be used by others without further inspection and negligent manufacture may foreseeably endanger life.
2. Whether Buick was relieved of its duty to inspect the automobile's component parts because the defective wheel was purchased from another reputable manufacturer.
3. Whether any error in the trial court's characterization of an automobile as not inherently dangerous required reversal.

Disposition

affirmed