Torts I, Page 262–263
Cruz v. DaimlerChrysler Motors Corp.
Supreme Court of Rhode Island, 2013
Facts:
Minivan owner was cleaning inside when both airbags suddenly deployed and injured him. They then sued the dealer on the doctrine of res ipsa loquitur.
Procedural History:
Trial judge granted defendant's motion for summary judgment on all counts.
Issue:
Is a car salesman liable for defects not discovered until years later under res ipsa loquitur?
Defendant's Argument:
Defendant did not know nor should have known of the defect.
Reasoning:
Defendant cannot be expected to know of a fault that did not manifest, or possibly even exist, until three years after he sold it.
Rule/Holding:
No, res ipsa loquitur cannot hold someone liable for a defect he did not cause and was not expected to know of.
Judgment:
Affirmed.