MacPherson v. . Buick Motor Co.
111 N.E. 1050 · New York Court of Appeals · 1916
Facts
The defendant, an automobile manufacturer, sold a car to a retail dealer. The dealer then resold this automobile to the plaintiff. While the plaintiff was driving the car, it suddenly collapsed, throwing him out and causing injuries. The collapse was due to a defective wooden wheel, whose spokes crumbled into fragments. Although the defendant did not manufacture the wheel itself, having purchased it from another company, evidence showed that the defect could have been discovered through a reasonable inspection, which the defendant omitted. The plaintiff's claim was based on negligence, not fraud or willful concealment of the defect.
Issue
The central legal question is whether an automobile manufacturer owes a duty of care to a consumer who purchased the vehicle from a retail dealer, rather than directly from the manufacturer. Specifically, the court must determine if the manufacturer's duty extends beyond the immediate purchaser.
Holding
The court held that the manufacturer did owe a duty of care to the plaintiff, a remote purchaser. It affirmed the judgment, establishing that a manufacturer can be held liable for negligence to an ultimate consumer even without a direct contractual relationship.
Rule
A manufacturer has a duty of care to remote purchasers if the product is reasonably certain to place life and limb in peril when negligently made. This duty arises when there is knowledge that the product will be used by persons other than the immediate purchaser, and used without new tests, making the manufacturer responsible for careful production irrespective of contract. The manufacturer of a finished product, who puts it on the market for use without inspection by customers, is liable for negligence where danger is foreseeable. This includes a duty to inspect component parts, even if purchased from another reputable manufacturer, as the manufacturer of the finished product is responsible for its overall safety. The principle extends beyond inherently destructive items to any product that becomes imminently dangerous due to negligent construction.
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