Greenman v. Yuba Power Products, Inc.

Facts

Greenman saw a Shopsmith demonstrated by the retailer. The Shopsmith was a combination power tool that could be used as a saw, drill and wood lathe. He also studied a brochure the manufacturer prepared. His wife bought one and gave it to him for Christmas in 1955. In 1957 he bought the attachments needed to use it as a lathe, to turn a large piece of wood into a chalice. After he had worked on the wood several times without difficulty, it suddenly flew out of the machine and struck him on the forehead, causing serious injuries. Some months later he gave the retailer and the manufacturer written notice of claimed breaches of warranty and sued both for breach of warranty and negligence. At trial his expert witnesses testified that inadequate set screws held parts of the machine together. Normal vibration moved the tailstock of the lathe away from the wood, which let the wood fly out. They also testified that other, more positive ways of fastening the parts existed and would have prevented the accident. The brochure also made statements about the machine's construction, which the jury could find untrue.

Issues

1. Was Greenman's warranty claim against the manufacturer barred under section 1769 of the Civil Code if he did not give notice of breach within a reasonable time?
2. Must an injured user prove an express warranty as the sales act defines it to hold the manufacturer strictly liable, or is proof that a defect in the product injured him enough?

Holding

The manufacturer was strictly liable. Greenman did not have to prove an express warranty or give sales act notice. It was enough that he was injured while using the Shopsmith as intended, because of a design and manufacturing defect he did not know about that made it unsafe for its intended use.