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MacPherson v. Buick: Difference between revisions

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{{Infobox Case Brief
{{Infobox Case Brief
|court=Court of Appeals of New York
|court=Court of Appeals of New York
|date=March 14, 1916
|date=1916-3-14
|subject=Contracts/Outline
|subject=Contracts
|case_treatment=No
|facts=MacPherson bought his [https://buickmodel10.com/ Buick Model 10] car for $900 in 1908 ([https://www.wolframalpha.com/input?i=US%24900+%281908+US+dollars%29 $30,300 in 2023]); the dealer had bought the car directly from Buick.
|facts=MacPherson bought his [https://buickmodel10.com/ Buick Model 10] car for $900 in 1908 ([https://www.wolframalpha.com/input?i=US%24900+%281908+US+dollars%29 $30,300 in 2023]); the dealer had bought the car directly from Buick.


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|issues=Does the manufacturer of a product owe a '''duty of care''' to anyone other than the initial purchaser?
|issues=Does the manufacturer of a product owe a '''duty of care''' to anyone other than the initial purchaser?
|holding=Yes. The manufacturer of a product owes a duty of care to users than the initial purchaser (here the car dealership).
|holding=Yes. The manufacturer of a product owes a duty of care to users than the initial purchaser (here the car dealership).
|rule=Duty of care for car manufacturers:
|rule=Duty of care for car manufacturers extends to later users if:


#the product is reasonably likely to create a danger if it's negligently manufactured
#the product is reasonably likely to create a danger if it's negligently manufactured
#the product will be used by people other than the original purchaser & without additional testing.
#the product will be used by people other than the original purchaser & without additional testing.
This is a modification of the '''rule of privity''' which states that the manufacturer only has a '''duty of care''' to the 1st purchaser (the dealership).
|case_text_links={{Infobox Case Brief/Case Text Link
|case_text_links={{Infobox Case Brief/Case Text Link
|link=https://www.nycourts.gov/reporter/archives/macpherson_buick.htm
|link=https://www.nycourts.gov/reporter/archives/macpherson_buick.htm
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}}{{Infobox Case Brief/Case Text Link
}}{{Infobox Case Brief/Case Text Link
|link=https://www.quimbee.com/cases/macpherson-v-buick-motor-co
|link=https://www.quimbee.com/cases/macpherson-v-buick-motor-co
|case_text_source=Quimbee video summary
|source_type=Video summary
|case_text_source=Quimbee
}}
}}
}}
}}

Latest revision as of 03:40, July 14, 2023

MacPherson v. Buick
Court Court of Appeals of New York
Citation
Date decided 1916-3-14

Facts

MacPherson bought his Buick Model 10 car for $900 in 1908 ($30,300 in 2023); the dealer had bought the car directly from Buick.

In July 1911, MacPherson was driving his car at 8 mi/h when his left rear wheel collapsed. His car spun out of control & he was injured. The cause of the wheel collapse was defective wood. Buick had purchased the wheel from a supplier. Apparently, Buick hadn't inspected the wheel before selling the car to the dealer.

Procedural History

MacPherson sued Buick, the automobile manufacturer, in a NY state court.

MacPherson lost, but the NY Appellate Division reversed the decision.

At the 2nd trial, MacPherson won a judgment of $5,000.

Issues

Does the manufacturer of a product owe a duty of care to anyone other than the initial purchaser?

Holding

Yes. The manufacturer of a product owes a duty of care to users than the initial purchaser (here the car dealership).

Rule

Duty of care for car manufacturers extends to later users if:

  1. the product is reasonably likely to create a danger if it's negligently manufactured
  2. the product will be used by people other than the original purchaser & without additional testing.
This is a modification of the rule of privity which states that the manufacturer only has a duty of care to the 1st purchaser (the dealership).

Case Text Links