Volkswagen of America, Inc. v. Young – Case Brief
Volkswagen of America, Inc. v. Young, 272 Md. 201, 321 A.2d 737 (1974).
Facts: Young had been driving a car manufactured by Volkswagen of America (D) and was stopped at a red light when a negligent driver hit him from behind. The seat bracketing pieces and adjustment mechanisms broke away and Young was thrown back into the rear compartment of the car. Young’s head and torso impacted into allegedly inadequate and defectively designed passenger compartment structures, surfaces and protrusions, thereby killing him.
Young’s mother and widow (P) sued Volkswagen, complaining that the car was defectively designed and manufactured and had defects that rendered it structurally hazardous, not merchantable, and not fit for the purpose intended. Volkswagen moved to have the following issues certified for decision by the Maryland Court of Appeals:
Issues: 1) Does “intended use” of a motor vehicle include involvement in a collision? 2) Can a manufacturer be held liable under breach of warranty, negligence, or absolute liability, if the design and manufacture of the vehicle unreasonably increases the risk of injury to occupants following a collision not caused by any defect of the vehicle?
Holding and Rule: 1) Yes. The “intended use” of an automobile is not merely to provide transportation, but to provide safe transportation. 2) Yes. A manufacturer can be held liable under breach of warranty, negligence, or absolute liability, if the design and manufacture of the vehicle unreasonably increases the risk of injury to occupants following a collision not caused by any defect of the vehicle.
One injured in an automobile accident has an action against the vehicle’s manufacturer if his injuries were the result of the manufacturer’s negligent defective design of the automobile. Automobile manufacturers should recognize that their cars will be involved in accidents and should manufacture their cars to be safe if an accident should occur. A manufacturer is liable for latent design defects that cause a ‘second collision’ or otherwise increase injury. These types of problems should not incur strict liability, but negligence can be established.
Disposition: As these issues were submitted for certification, see holding and rule.