Summary of Ford Motor Co. v. Matthews, S. Ct Mississippi [1974]

Defenses

Relevant Facts: Matthews was killed as a result of being run over by his tractor and dragged underneath a disc attachment.  He was standing beside the tractor when he started it and the tractor was in gear at the time.  The tractor was equipped with a starter safety switch which was designed to prevent the tractor from being started in gear.

Legal Issue(s): Whether Pl Matthew’s alleged negligence or misuse is a bar to recovery for strict liability?

Court’s Holding: No

Procedure: Bench trial verdict for Pl, Ford appealed.  Judgment Affirmed.

Law or Rule(s): A product is not in a defective condition when it is safe for normal handling and consumption. If the injury results from abnormal handling * * * the seller is not liable.

Court Rationale: Although misuse of a product that causes an injury is normally a bar to strict liability, it is said that “The manufacturer is not liable for injuries resulting from abnormal or unintended use of his product, if such use was not reasonably foreseeable.  The issue is one of foreseeability and misuse may be foreseeable.  These are factual issues of foreseeability of a particular use that are left to the jury.  The tractor was designed to prevent its starting in gear.  It could be foreseeable by Ford that one day a tractor operator might carelessly crank the engine w/o first making certain that it was not in gear, especially if he were aware of the purpose of the safety switch system.  Even if Pl were negligent, such negligence was reasonably foreseeable by Ford and is not a bar to an action based on strict liability resulting from a defective tractor.

Plaintiff’s Argument: The plunger connected to the safety switch was defective and allowed the tractor to be started in gear.

Defendant’s Argument: Pl’s act of standing on the ground and starting the tractor while in gear was a misuse of the product.