Macpherson v. Buick Motor Co.

• Author: Jeffrey Lehman, Shirelle Phelps

Page 385

A famous 1916 New York Court of Appeals decision, MacPherson v. Buick Motor Co., 217 N.Y. 382, 111 N.E. 1050, expanded the classification of "inherently dangerous" products and thereby effectively eliminated the requirement of privity?a contractual relationship between the parties in cases that involve defective products that cause personal injury.

The Buick Motor Company manufactured automobiles that it sold to retailers who, in turn, sold them to consumers. The plaintiff, Donald MacPherson, bought a car from a dealer and was subsequently injured when the car collapsed during a drive. The accident was due to a defective wheel, which the defendant, Buick, did not make but purchased from another manufacturer. Evidence indicated that the defect could have been discovered by reasonable inspection, but none took place. The plaintiff sued the defendant for his personal injuries, but the defendant claimed that it was not liable for the wheel manufacturer's NEGLIGENCE. The state trial and intermediate appellate courts found for the plaintiff, and the defendant appealed to the Court of Appeals, the highest court of New York. The court narrowed the issue to whether the defendant owed a duty to anyone but the retailer to whom it sold the car.

In a majority opinion written by BENJAMIN CARDOZO, the court affirmed the judgment for the plaintiff. Since the defendant was a manufacturer of automobiles that, if defective, are inherently dangerous by virtue of their existence, it had a responsibility for the finished product, which included testing its various parts before placing it on the market for sale. The manufacturer could not avoid liability based upon the fact that it purchased the wheels from a reputable manufacturer, because it had a duty to inspect the car, which it failed to do. The defendant argued that since poisons, explosives, or comparable items that are normally...