Camacho v. Honda Motor Co.

Facts

In March 1978, Jaime Camacho bought a new Honda Hawk motorcycle from a Honda dealer. Honda Motor Co., Ltd. made the motorcycle, and American Honda Motor Co., Inc. distributed it. In May 1978, Camacho was riding through an intersection when he collided with an automobile. He suffered serious leg injuries. The motorcycle had no crash bars, which are tubular steel bars attached to the frame to protect the rider's legs in a collision. Camacho and his wife sued Honda for damages, including damages for personal injuries, property losses, loss of consortium and exemplary damages. Among other theories, they claimed the motorcycle was defectively designed and unreasonably dangerous because it lacked crash bars. Two mechanical engineers they hired testified in depositions that effective leg protection devices were feasible in March 1978 and that several other manufacturers offered them as optional equipment. They also testified that those devices would have reduced or avoided Camacho's injuries. They added that Honda's own research in 1969 led its engineers to conclude that injury-reducing crash bars could be made by strengthening the steel bars tested and using strong bolts. It was undisputed that in March 1978 Honda did not offer leg protection devices as original equipment on any motorcycle it sold in the United States.

Issues

1. Does the crashworthiness doctrine, which allows liability for a defect that caused or enhanced injuries in an accident it did not cause, apply to motorcycle manufacturers as it does to automobile manufacturers?
2. Is the consumer contemplation test of comment i to section 402A, which asks whether the danger was beyond what an ordinary consumer would contemplate, the proper way to decide whether a design is unreasonably dangerous in Colorado?
3. Was summary judgment proper for Honda where Honda disputed the Camachos' expert evidence on crash bars?

Holding

The crashworthiness doctrine applies to motorcycle manufacturers. The consumer contemplation test used below was the wrong standard for deciding whether the motorcycle was unreasonably dangerous. Because Honda strenuously disputed the Camachos' experts' conclusions about crash bars, summary judgment for Honda on the reasonableness of its design was improper.