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MacPherson v. Buick Motor Co. (1916) is a landmark product liability case that established the principle that manufacturers owe a duty of care to ultimate consumers, even without privity of contract. This case revolutionized tort law by eliminating the privity requirement for negligence claims against manufacturers of inherently dangerous products.
MacPherson v. Buick Motor Co., 217 N.Y. 382, 111 N.E. 1050 (N.Y. 1916)
Donald MacPherson purchased a Buick automobile from a retail dealer. The car was manufactured by Buick Motor Company, which had purchased the wooden wheels from another manufacturer. While MacPherson was driving, one of the wooden wheels collapsed due to defective spokes, causing the car to overturn and injure MacPherson.
MacPherson had no direct contractual relationship (privity of contract) with Buick Motor Company, as he purchased the car from a dealer. Under traditional contract law, this lack of privity would have barred any claim against the manufacturer.
Evidence showed that Buick could have discovered the defect through reasonable inspection but failed to do so before selling the automobile to the dealer.
Can a manufacturer be held liable in negligence to an ultimate consumer who was injured by a defective product, even though there is no privity of contract between the manufacturer and the consumer?
A manufacturer owes a duty of care to any person who may be injured by a product if the product is reasonably certain to place life and limb in peril when negligently made. This duty exists regardless of privity of contract between the manufacturer and the injured party.
Yes. The court held that Buick Motor Company owed a duty of care to MacPherson despite the lack of privity of contract. The manufacturer was liable for negligence because automobiles are inherently dangerous when defectively manufactured, and the manufacturer had a duty to inspect for defects.
Judge Cardozo, writing for the court, reasoned that the traditional privity requirement should not shield manufacturers from liability when they produce inherently dangerous products. The court established several key principles:
The court distinguished this case from earlier precedents that required privity, noting that those cases involved products that were not inherently dangerous or where the manufacturer had no reason to expect the product would be used by third parties.
MacPherson v. Buick Motor Co. is one of the most important tort law cases in American legal history. Its significance includes:
The decision paved the way for the development of strict product liability and influenced product safety standards across industries. It remains a cornerstone case in tort law and is studied in virtually every American law school.
The privity requirement meant that only parties in direct contractual relationship could sue each other. A consumer who bought from a retailer could not sue the manufacturer because there was no direct contract between them.
The court found that automobiles, when defectively manufactured, pose significant risks to life and limb. Their speed, weight, and complexity make them potentially dangerous if not properly constructed and inspected.
MacPherson established that manufacturers owe duties directly to consumers, not just to immediate purchasers. This created the legal foundation for modern product liability, allowing injured consumers to sue manufacturers directly.
Judge Benjamin Cardozo wrote the majority opinion, demonstrating judicial innovation by adapting common law principles to modern industrial conditions. His reasoning became a model for legal evolution.
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