Introduction

Parties Involved: This case involves Albert L. Blevins and Linda Blevins (Plaintiffs-Respondents) versus Cushman Motors, a division of Outboard Marine Corp. (Defendant-Appellant).

Background: On July 15, 1969, Albert Blevins was injured in a golf cart accident caused by a defective design of a three-wheeled golf cart manufactured by Cushman. The accident resulted in severe physical injuries to Mr. Blevins, leading him and his spouse to file a products liability lawsuit under the theory of strict liability in tort.

Key Issues: The central issues on appeal included the applicability of strict liability in tort to defective design cases, the sufficiency of the plaintiffs' case, admissibility of expert testimony and advertisements, and procedural matters related to jury instructions and conduct.

Summary of the Judgment

The Supreme Court of Missouri upheld the verdict in favor of the plaintiffs, Albert and Linda Blevins. The jury awarded $73,000 to Albert Blevins for personal injuries and $21,000 to Linda Blevins for loss of consortium. Cushman Motors' appeal was denied, confirming that strict liability in tort is applicable in cases of defective product design. The court affirmed that the plaintiffs had established a submissible case based on the evidence presented, including expert testimony demonstrating the golf cart's defective design.

Analysis

Precedents Cited

The judgment heavily relied on several key precedents to establish the applicability of strict liability in tort to defective design cases:

• Keener v. Dayton Electric Mfg. Co. (1969): Recognized the concept of strict liability in tort as per the Restatement (Second) of Torts § 402A.
• GREENMAN v. YUBA POWER PRODUCTS, INC. (1963): Established that manufacturers are liable under strict liability for defects that make products unreasonably dangerous.
• Additional cases from various jurisdictions affirmed the applicability of strict liability to defective design, ensuring uniformity across different legal landscapes.

Legal Reasoning

The court delineated the difference between strict liability and negligence in the context of defective design:

• Strict Liability: Focuses on the product's condition, asserting liability if the product is unreasonably dangerous, regardless of the manufacturer's intent or care.
• Negligence: Centers on the manufacturer's reasonable care in designing and producing the product, assessing whether they failed to prevent foreseeable harm.

The court concluded that the defective design of the golf cart made it unreasonably dangerous for its intended use. Factors such as the cart's stability and design flaws were critical in establishing the manufacturer's liability under strict liability.

Impact

This judgment reinforces the principle that manufacturers are held strictly liable for defective product designs that render their products unreasonably dangerous. It provides a clear legal pathway for plaintiffs to seek redress without the burden of proving negligence, thus potentially increasing accountability among manufacturers for product safety.

Complex Concepts Simplified

Conclusion

Blevins v. Cushman Motors stands as a significant precedent in Missouri's legal landscape, affirming the applicability of strict liability in tort to defective product designs. By upholding the jury's verdict, the Supreme Court of Missouri underscored the responsibility of manufacturers to ensure the safety of their products. This case serves as a crucial reference point for future products liability cases, emphasizing that manufacturers must prioritize safety in design to avoid strict liability for resulting injuries.