Introduction
In the Greenman v. Yuba Supreme Court case, the plaintiff is William B. Greenman, and the defendant is the commercial company Yuba Power Products, Inc. Greenman sued the manufacturer because of the attachment to his Shopsmith power tool, produced by Yuba, after a short time of impeccable functioning and injured him by throwing a piece of wood he was working with.
The position taken by the defendant was that the plaintiff overlooked the defects of the power tool on time, and this was treated as a sufficient reason not to decline his warranty claim. The main issue of the Greenman v. Yuba case is whether the defendant is strictly liable in tort if the manufactured product occurs to be defective. The court granted the plaintiff’s motion and ruled in favor of the retailer where the Shopsmith and the attachments were purchased, whereas Yuba Power Products was held strictly liable in tort.
History
As the result of the trial before the jury, the court acquitted the third party of this conflict – the retailer where Mr. Greenman and his wife purchased a Shopsmith and the accomplishing details. Instead, it had been proven that the actions of the retailer could not anyhow affect the quality and the safety of the purchased good (Freeman, 2016). This decision is based on the absence of evidence of the retailer’s breach of warranty. Yuba Power Products also was not found guilty of a warranty breach. The jury verdict was that the manufacturer should award the plaintiff $65,000. After this trial, Mr. Greenman and Yuba lodged an appeal and the former provided sufficient evidence that the experienced injury resulted from the defects in some of Shopsmiths details.
This evidence was based on the opinion of experts who revealed that, indeed, the construction utilized by the manufacturer was not efficient and safe and caused the discussed incident. More precisely, the independent experts discovered that the screws did not hold the lathe parts as tight as expected (59 Cal. 2d 57, 377 P.2d 897, 27 Cal. Rptr 697, 1963). Furthermore, Mr. Greenman did not face any issues with the tool from the very beginning because it took some time for the inadequate screws to loosen the connection between the machine elements. In addition, the expertise had proven that the defendant did not check its products for defects before putting them on the market. Therefore, the brochure attached to Shopsmiths misleads the consumers since it does not reflect the actual condition of the tool.
Decision
The ultimate decision of the Supreme Court was that Yuba Power Products is strictly liable in tort. This decision is based on the fact that even though the defendant was aware that the produced goods were not properly inspected and might contain life- and health-threatening defects, it still placed them on the market. At the same time, the primary reason for concern, in this case, was section 1769 of the Civil Code, according to which a seller is liable for all the damage caused by its products (59 Cal. 2d 57, 377 P.2d 897, 27 Cal. Rptr. 697, 1963). However, this rule works until a buyer “fails to give notice to the seller of the breach of any promise or warranty within a reasonable time after the buyer” reveals the flaws of the purchased good (59 Cal. 2d 57, 377 P.2d 897, 27 Cal. Rptr. 697, 1963, p. 3). An ordinary person typically is not aware of these limits and, therefore, a company could use this hole in the law system for its advantage. Besides, the Supreme Court could have referred to this section of the Civil Code to rule in favor of the manufacturer.
Reasoning
The fact that the manufacturer sold a potentially harmful product and gave misleading promises of its safety is more important than that the plaintiff informed Yuba of the problem ten months after the incident. In its decision, the court emphasizes the significance of the concept of strict product liability and claims that “strict liability in tort did not depend on the presence of a contractual warranty” (Block-Lieb & Janger, 2021, p. 10). The key idea behind the strict product liability concept is that an injured party should prove that the product that caused the damage was originally defective and that the cause of the damage lies precisely in these defects. As it has already been mentioned above, the experts who analyzed the Shopsmith machine utilized by Mr. Greenman found significant flaws in its construction. This enabled the court to utilize the principle of strict product liability.
The Greenman v. Yuba Supreme Court case could be regarded as an essential milestone in judicial history. As Lindenfeld and Tran (2016) put it, this case “was a catalyst for the adoption of strict product liability” (p. 117). Another insight provided by this trial is that the rules established for warranties are not applicable to the issues of liability and safety of products. Indeed, if Mr. Greenman’s machine ceased to function without putting his physical well-being in threat and he informed of the problem ten months later, it would have been rational to find the manufacturer unguilty. That is because, in such a case, the company does not break its promises on the product’s safety and accuracy listed in the brochure. In contrast, the plaintiff failed the warranty agreement between the two parties. Nonetheless, in the discussed case, the breakdown of Shopsmith tuned in the hospitalization of the buyer. This way, the late petition on the problem is merely an excuse to avoid responsibility for the quality of the produced staff.
Dissenting and Personal Opinions
The decision that was made in Greenman v. Yuba case could hardly be criticized because the latter side of the conflict was found guilty of the conscious violation of safety standards for the manufactured product. From this perspective, it is fair to hold manufacturers strictly liable for the quality of their commodities. What is more, it is unforgivable to neglect quality control procedures, and those who are involved in the damage caused should get their punishment. Even though the concepts of warranty and liability are closely related, it is still necessary to distinguish between them. I also agree with the decision that was put forward by the Supreme Court and believe that it is impossible to omit a company’s responsibility for quality. This case is a valuable legal precedent that helped introduce a new and more rational understanding of liability.
Conclusion
The Greenman v. Yuba Supreme Court case represents a peculiar situation that shows that manufacturers could manipulate the law to avoid responsibility for the incidents. The decision of the court concerning Yuba Power Products is rational and legitimate because it is based on a thorough analysis of its goods and the manufacturing process. The critical point is that the consumer, who was injured by the machine, was not informed of the existing defects and expected that his Shopsmith power tool would be totally safe. Finally, the existence of such a court precedent as the case of Greenman v. Yuba raises the sense of responsibility in the producers because it makes it difficult to escape the punishment in the instances when safety and construction violations have been identified.
References
59 Cal. 2d 57, 377 P.2d 897, 27 Cal. Rptr. 697 (1963). Greenman v. Yuba Supreme Court Case.
Block-Lieb, S., & Janger, E. J. (2021). Fit for its Ordinary Purpose: Implied Warranties and Common Law Duties for Consumer Finance Contracts. Houston Law Review, 1-56.
Freeman, R. E. (2016). A stakeholder theory of the modern corporation. In Max B.E. Clarkson (Ed.), The corporation and its stakeholders (pp. 125-138). University of Toronto Press.
Lindenfeld, E., & Tran, J. L. (2016). Prescription drugs and design defect liability: Blanket immunity approach to the increased costs and unavailability of prescription medication. Drake Law Review, 64, 111-139.