Soule v. General Motors Corporation

1994

Venue: CA SC
Facts: Plaintiff's car collides with another vehicle. The left front wheel breaks free, collapses rearward, smashes the floorboard and her feet.
Posture: Verdict for plaintiff at trial, affirmed on appeal.
Issue: May a product's design be found defective because it fails to meet an ordinary consumer's expectation of safety, even if the question of how safely the product should have performed is unanswerable by the common experience of its users?
Holding: No. But the error was not prejudicial, so affirmed.
Rule: Consumer expectations are irrelevant in a case this complex. In cases where they are relevant, expert testimony is not needed. The standard is that the plaintiff must show:
  1. That the product failed to perform as safely as an ordinary consumer would expect
  2. That the defect existed when the product left the manufacturer's possession
  3. That the defect was a "legal cause" of the plaintiff's "enhanced injury"
  4. That the product was used in a reasonably foreseeable manner.
In a highly complex design case, it doesn't make sense to give weight to ordinary peoples' expectations. It's just not expectable.
Reasoning: Consumers govern their actions by their expectations of product safety, so where products are simple, it makes sense to use this as a standard for whether the product performed acceptably. But a complex product may still be defective if its design embodies excessive preventable danger.

The consumer expectations test is only fit for cases where the everyday experience of a product's users permits a conclusion that the design violated minimum safety assumptions. This precludes the use of expert testimony: by definition, experts offer knowledge outside ordinary experience.

Manufacturers are not insurers of products: they are liable in tort only when a defect in their products causes injury

The theory of defect here was one of technical and mechanical detail. An ordinary consumer couldn't reasonably be expected to have thoughts along these lines.

At the same time, though, the consumer expectations theory wasn't a big deal here, and didn't affect the outcome.
Dicta: