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.

Judgment:

Affirmed.

Rule/Holding:

No, res ipsa loquitur cannot hold someone liable for a defect he did not cause and was not expected to know of.