Can a third party who was not the original purchaser of an automobile sue the manufacturer for injuries caused by defects in the vehicle?

The plaintiff sustained injuries when a wheel collapsed on an automobile he was riding in, which was manufactured by Buick Motor Company. Buick had sold the car to a dealer in Schenectady, who then sold it to the plaintiff. The faulty wheel was purchased by Buick from Imperial Wheel Company, a reputable manufacturer from whom Buick had previously acquired 80,000 wheels without issue. Buick relied on Imperial Wheel Company to conduct necessary tests and did not perform its own inspections.

The accident occurred while the car was traveling at only 8 miles per hour. There was no evidence that Buick had actual knowledge of the defect, nor was there any indication of fraud or misrepresentation in the sale. Buick had not conducted its own tests on the wheels, instead trusting the wheel manufacturer's quality control processes.

The plaintiff initially brought the case in a lower court, where it was presented to a jury for deliberation. The jury rendered a verdict in favor of the plaintiff. Following this decision, the defendant appealed the case to the Appellate Division. The Appellate Division reviewed the lower court's rulings and upheld them. Subsequently, the case progressed to its current venue, the New York Court of Appeals, for further review and adjudication.

(Cardozo, J.)

Yes. A third party who was not the original purchaser of an automobile can sue the manufacturer for injuries caused by defects in the vehicle. The duty of care owed by a manufacturer extends beyond the immediate purchaser to anyone who might foreseeably use the product. Privity of contract is not necessary for liability in cases involving potentially dangerous articles. When a manufacturer places a finished product on the market, knowing it will be used without inspection by the purchaser, the manufacturer assumes a duty to conduct that inspection. This duty applies not only to inherently dangerous products but to any product that could become dangerous if negligently manufactured. The law has evolved to recognize an expanded scope of liability in such cases, moving away from strict privity requirements. This extension of liability is based on the principle that manufacturers are best positioned to prevent defects and ensure product safety. The foreseeability of harm to end-users, regardless of their direct contractual relationship with the manufacturer, is a key factor in establishing this duty. Public policy considerations support this approach, as it incentivizes manufacturers to prioritize safety in design and production. The potential for harm from defective automobiles is significant, and limiting liability to only direct purchasers would leave many injured parties without recourse. This broader conception of manufacturer liability aligns with modern understanding of product distribution chains and consumer protection principles.

Dissent (Bartlett, J.) The majority's decision extends liability further than any previous case in New York. The established rule limiting liability to the original parties of the contract should be maintained. Any changes to this rule should be made by the legislature, not the courts. This expansion of liability creates uncertainty in commercial relationships and may have far-reaching consequences for manufacturers and retailers. The court is overstepping its bounds by effectively creating new law rather than interpreting existing statutes and precedents.