West Case Update

Manufacturing Defect Different from Design Defect in Products Liability Action

Description Appeals court held that a suit by a vehicle owner, who was injured when his vehicle's engine caught fire, could proceed. While the owner failed to show a design defect, which requires a showing of a safer design alternative, the owner does have a suit for a manufacturing defect that might be the cause of the injury.

Topic Torts

Key Words Products Liability; Manufacturing Defect; Design Defect

C A S E S U M M A R Y

Facts Ridgway suffered severe burns when his 1995 Ford F-150 pickup burst into flames while he was driving it in 1997. The fuel system had been repaired three times. Ridgway sued for products liability, contending that the vehicle was defective. An expert testified that there was an electrical malfunction that caused the fire to start in the engine block. Ford contended that there was no evidence of a product defect or a safer design alternative. The trial court dismissed the suit. Ridgway appealed.

Decision
Reversed. Summary judgment was not proper since there is a genuine issue of material fact regarding whether the fire resulted from a manufacturing defect or not. If there is no direct evidence of any specific defect, the plaintiff may offer evidence of the malfunction as circumstantial proof of the manufacturing defect. To claim design defect, the plaintiff would have to offer a safer alternative design; that is a separate issue from a manufacturing defect. A design defect occurs when the product's design itself makes the product unsafe. Ridgway does not have to prove design defect to win a suit for manufacturing defect.

Citation Ridgway v. Ford Motor Co., — S.W.3d — (2002 WL 121820, Ct. App., Tex., 2002)

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Manufacturing Defect Different from Design Defect in Products Liability Action
Description	Appeals court held that a suit by a vehicle owner, who was injured when his vehicle's engine caught fire, could proceed. While the owner failed to show a design defect, which requires a showing of a safer design alternative, the owner does have a suit for a manufacturing defect that might be the cause of the injury.
Topic	Torts
Key Words	Products Liability; Manufacturing Defect; Design Defect
C A S E S U M M A R Y
Facts	Ridgway suffered severe burns when his 1995 Ford F-150 pickup burst into flames while he was driving it in 1997. The fuel system had been repaired three times. Ridgway sued for products liability, contending that the vehicle was defective. An expert testified that there was an electrical malfunction that caused the fire to start in the engine block. Ford contended that there was no evidence of a product defect or a safer design alternative. The trial court dismissed the suit. Ridgway appealed.
Decision	Reversed. Summary judgment was not proper since there is a genuine issue of material fact regarding whether the fire resulted from a manufacturing defect or not. If there is no direct evidence of any specific defect, the plaintiff may offer evidence of the malfunction as circumstantial proof of the manufacturing defect. To claim design defect, the plaintiff would have to offer a safer alternative design; that is a separate issue from a manufacturing defect. A design defect occurs when the product's design itself makes the product unsafe. Ridgway does not have to prove design defect to win a suit for manufacturing defect.
Citation	Ridgway v. Ford Motor Co., — S.W.3d — (2002 WL 121820, Ct. App., Tex., 2002)