Holloway v. General Motors Corp.

271 N.W.2d 777, 403 Mich. 614, 1978 Mich. LEXIS 217
CourtMichigan Supreme Court
DecidedDecember 4, 1978
Docket57139, (Calendar Nos. 1, 7)
StatusPublished
Cited by60 cases

This text of 271 N.W.2d 777 (Holloway v. General Motors Corp.) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Holloway v. General Motors Corp., 271 N.W.2d 777, 403 Mich. 614, 1978 Mich. LEXIS 217 (Mich. 1978).

Opinions

Levin, J.

Rehearing was granted to resolve the equal division of this Court following a prior submission of this cause. Holloway v General Motors Corp, 399 Mich 617; 250 NW2d 736 (1977). The trial court directed a verdict of no cause of action in favor of General Motors on the ground that the Holloways had failed to establish a defect in the ball joint assembly of the automobile. The Court of Appeals affirmed.

Both opinions on the prior submission are in agreement that a plaintiff may establish by circumstantial as well as direct evidence that there was a defect in the product when it left the manufacturer. The disagreement is whether it would be reasonable to infer such a defect from the circumstantial evidence in the instant case.

We conclude that it would be reasonable to draw such an inference.

We have also considered General Motors’ further contention, on rehearing, that a failure attributable to the manufacturer is not proven unless the specific cause of the defect is identified. We conclude that, although the specific cause was not so isolated, the Holloways satisfied their burden when they presented evidence from which the jury could reasonably infer that some defect in manufacture caused the accident.

[619]*619We reverse and remand for a new trial.

I

On May 28, 1971, Ernest Holloway was driving at a speed of approximately 50 to 55 miles per hour along a gravel road in Eaton County when his automobile left the road. The vehicle struck a utility pole. Holloway was killed and his daughter, Brenda, seriously injured. The automobile was four years old, had been driven over 47,000 miles, and there were two previous owners. The Holloways alleged that the accident was caused by a defective ball joint assembly in the right front suspension which broke while the automobile was traveling over chuckholes in the road.

Sharon Holloway, as administratrix of her deceased husband’s estate and as next friend of her daughter, commenced this action against General Motors and other defendants. The trial judge granted General Motors’ motion for a directed verdict;1 on appeal, the Court of Appeals affirmed in a split decision on the ground that a manufacturing defect had not been proven. This Court affirmed by a 3 to 3 division. The Holloways’ application for rehearing was granted.

II

On the prior submission, one of the issues was [620]*620whether the ball joint assembly of the Holloway automobile failed while it was on the roadway, as contended by the Holloways, or after it hit a ditch and then a utility pole,2 as contended by General Motors. If the assembly did not break until after the automobile left the roadway that would indicate the cause of the failure was not a defect in the manufacture but, rather, the driver’s loss of control of the automobile and its impact against the ditch or pole.

The opinion for affirmance did not find it necessary to consider that issue because it concluded that, in all events, the circumstantial evidence was insufficient to support an inference of a manufacturing defect. The opinion for reversal concluded that there was sufficient evidence from which the trier of fact could conclude that the break in the assembly occurred on the roadway and, thus, that the break was not a result of the driver’s loss of control of the automobile.

Although General Motors continues to argue that it would be more reasonable to infer from certain circumstantial evidence that the break occurred after the automobile left the roadway, it has conceded, for the purposes of this rehearing, that the break occurred on the roadway.3

Ill

We therefore proceed on the premise that it would be reasonable to infer that the ball joint assembly failed on the roadway before the driver lost control of the automobile and, thus, that the [621]*621assembly was defective. Proceeding on that premise, it is also reasonable to infer that the defect in and failure of the assembly caused the accident.4

The still-disputed issue is whether that defect was shown to have been attributable to the manufacturer.5

A plaintiff has the burden of establishing that when the product left the manufacturer it was defective. He is not, however, obliged to eliminate all possible causes of the accident consistent with the view that there was no manufacturing defect.6 He sustains his burden when he establishes with direct or circumstantial evidence a reasonable probability that the defect is attributable to the manufacturer.7

[622]*622On a motion for directed verdict, the question is whether it is reasonable to infer from the evidence, direct or circumstantial, that the accident was probably caused by a defect attributable to the manufacturer. Questions of comparative probability are to be resolved by the trier of fact.8 As stated in Schoepper v Hancock Chemical Co, 113 Mich 582, 586, 589; 71 NW 1081 (1897), and since reaffirmed in Schedlbauer v Chris-Craft Corp, 381 Mich 217, 230-231; 160 NW2d 889 (1968):

"It is true that where an injury occurs that cannot be accounted for and where the occasion of it rests wholly in conjecture, the case may fail for want of proof. * * * But such cases are rare, and that rule should never be so extended as to result in a failure of justice, or in denying an injured person a right of action where there is room for balancing the probabilities, and for drawing reasonable inferences better supported upon one side than upon the other. * * * [T]he question of whether the inference suggested by the plaintiff’s theory is the correct one, or whether it was sufficiently rebutted, was for the jury. ” (Emphasis supplied.)9

The opinion for reversal on the prior submission of this cause similarly declared:

"Although the strength of an inference that the accident was caused by a manufacturing defect depends on the plausibility of competing explanations for the accident, plaintiffs did not have the burden of proving that the accident could only be attributable to a manufacturing defect or 'of effectively eliminating any other factors or circumstances which could have been respon[623]*623sible for the failure.’ It was enough that they indicated 'a logical sequence of cause and effect * * * notwithstanding the existence of other plausible theories with or without support in the evidence.’ Schedlbauer v Chris-Craft Corp, 381 Mich 217, 220, fn 1; 160 NW2d 889 (1968). They were 'not required to offer evidence which positively exclude[s] every other possible cause of the accident.’ Swensson v New York, Albany Despatch Co, 309 NY 497, 502; 131 NE2d 902, 904 (1956).”10

IV

The opinion for reversal on the prior submission contrasted a defect in a wheel assembly with a failure in a part of the automobile subject to periodic maintenance, e.g., the braking system:11

"Wheel assemblies are not expected to wear out and be replaced.

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Cite This Page — Counsel Stack

Bluebook (online)
271 N.W.2d 777, 403 Mich. 614, 1978 Mich. LEXIS 217, Counsel Stack Legal Research, https://law.counselstack.com/opinion/holloway-v-general-motors-corp-mich-1978.