Can a consumer sue a product manufacturer for injuries caused by a defective product even if they didn't directly purchase it from the manufacturer?

William B. Greenman purchased a Shopsmith, a combination power tool, from a retailer after seeing a demonstration and studying a brochure. The tool was manufactured by Yuba Power Products, Inc. Greenman's wife bought it for him as a Christmas gift in 1955. Two years later, in 1957, Greenman was using the Shopsmith as a lathe when a piece of wood flew out and struck him on the forehead, causing serious injuries.

Greenman subsequently filed a lawsuit against both the retailer and the manufacturer, alleging breach of warranties and negligence. During the legal proceedings, expert witnesses provided testimony indicating that the accident was caused by inadequate set screws used to hold parts of the machine together. These substandard components allowed normal vibration to cause the tailstock to move away from the wood being turned, resulting in the incident that injured Greenman.

The plaintiff brought suit against a retailer and manufacturer. At trial, the court dismissed certain claims, allowing only breach of implied warranty claims against the retailer and negligence and breach of express warranty claims against the manufacturer to proceed to the jury. The jury found in favor of the retailer but awarded the plaintiff $65,000 against the manufacturer. The manufacturer's motion for a new trial was denied, and the court entered judgment based on the jury's verdict. Subsequently, both the manufacturer and the plaintiff filed appeals.

(Traynor, J.)

Yes. A consumer can sue a product manufacturer for injuries caused by a defective product even without direct purchase from the manufacturer.

Strict liability in tort applies when a manufacturer places an article on the market, knowing it will be used without inspection for defects, and that article proves to have a defect causing injury. This liability is imposed by law, not assumed by agreement, eliminating the need for privity between the injured party and the manufacturer. The purpose is to ensure manufacturers, not powerless consumers, bear the costs of injuries from defective products. This principle extends the chain of liability beyond immediate purchasers to any foreseeable user of the product. The traditional barriers of privity and express warranty requirements are removed, recognizing the reality of modern distribution chains where consumers rarely purchase directly from manufacturers. Public policy demands this extension of liability to protect consumers and incentivize manufacturers to produce safe products. The notice requirement under Civil Code Section 1769 is inapplicable in actions by injured consumers against manufacturers with whom they have not dealt directly, further emphasizing the broad scope of this liability. This rule effectively places the burden on manufacturers to ensure the safety of their products throughout the entire stream of commerce, regardless of the specific path a product takes to reach the end user.