BUS-FPX3021 Fundamentals of Business Law Case Law Analysis and Executive Briefing
Introduction:
The landmark case, MacPherson v. Buick Motor Co., set a precedent in the field of product liability and corporate responsibility. Decided by the New York Court of Appeals in 1916, this case marked a significant shift in how courts view the obligations of manufacturers toward consumers. This case is critical for businesses today as it highlights the importance of quality control and ethical practices in ensuring consumer safety.
Background: Facts of the Case
Donald C. MacPherson purchased a 1909 Buick Runabout from a dealership, which had acquired the vehicle from Buick Motor Company. While using the car, one of its wheels suddenly failed, leading to MacPherson sustaining injuries. Importantly, Buick did not manufacture the defective wheel, yet the court found Buick responsible for the failure. The New York Court of Appeals determined that Buick should have identified the defect with basic testing procedures, holding the company accountable for ensuring the safety of all vehicle components.
Buick contended that the dealership should be responsible for the incident, as it was the immediate seller. However, the court ruled that Buick Motor Co., as the manufacturer, had a higher duty of care. The ruling stated that Buick had an obligation to inspect and ensure the quality of the parts, even if they were outsourced, to prevent their product from becoming “imminently unsafe.”
Court Ruling: Expanding the Scope of Manufacturer Liability
The central issue in the case revolved around whether Buick owed a duty of care only to the immediate purchaser (the dealership) or to anyone who might use the product. In a landmark decision, Judge Cardozo, writing for the majority, declared that manufacturers have a duty of care to the end-users of their products, not just the direct buyer. This ruling drew from earlier cases such as Thomas v. Winchester, which had established that manufacturers of dangerous goods like poisons had a duty to protect consumers.
The court emphasized that although a car is not inherently dangerous, if improperly manufactured, it could pose serious risks. The decision stressed that manufacturers like Buick must conduct “ordinary and easy testing” to ensure that any defects in their products do not pose a risk to the user. Thus, Buick could not limit its liability to just the dealer.
In contrast, Chief Judge Bartlett’s dissent argued that the responsibility should rest with the actual manufacturer of the defective part, not Buick, which had merely assembled the vehicle. However, this view did not prevail, and the majority opinion significantly expanded the obligations of manufacturers.
References
Zipursky, B. C., & Goldberg, J. C. P. (2016). The Myths of Macpherson. FLASH: The Fordham Law Archive of Scholarship and History. https://ir.lawnet.fordham.edu/ faculty_scholarship/896/.
BUS FPX 3021 Assessment 2 Case Law Analysis and Executive Briefing
Macpherson v Buick. (n.d.). Retrieved October 4, 2022, from https://www.nycourts.gov/reporter/archives/macpherson_buick.htm
MacPherson v Buick Motor Co. 217 N.Y. 382, 111 N.E. 1050 (1916)