Moraca v. Ford Motor Co.

332 A.2d 599, 66 N.J. 454, 1975 N.J. LEXIS 224
CourtSupreme Court of New Jersey
DecidedFebruary 6, 1975
StatusPublished
Cited by65 cases

This text of 332 A.2d 599 (Moraca v. Ford Motor Co.) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moraca v. Ford Motor Co., 332 A.2d 599, 66 N.J. 454, 1975 N.J. LEXIS 224 (N.J. 1975).

Opinions

The opinion of the Court was delivered by

Sullivan, J.

In this products liability case involving a Lincoln Continental which was six months old at the time of the one car accident, a judgment in favor of defendants based upon a jury verdict of no cause was reversed by the Appellate Division, one judge dissenting, on the ground that the trial court’s charge to the jury was erroneous. A new trial on liability was ordered. See Moraca v. Ford Motor Co., 132 N. J. Super. 117 (1974). Because of the dissent, defendants appeal as of right. R. 2:2~l(a) (2). We affirm substantially for the reasons expressed in the majority opinion of the Appellate Division.

Plaintiff Thomas Moraca sustained serious injuries while driving his Lincoln Continental when it skidded off the road and ran into a tree. Plaintiff sued the Ford Motor Company and the Ford dealer from whom he had purchased the car claiming a manufacturer’s defect in the car’s steering system.1

At trial plaintiff not only attempted to show a specific defect in the steering mechanism of the vehicle, but also requested the trial court to charge the jury that plaintiff [457]*457was entitled to a verdict if he produced evidence from which a jury might reasonably infer that the accident was caused by some defect in the ear, whether identifiable or not, which existed prior to sale. In the same vein, plaintiff requested the further charge that liability may be established where the total effect of the circumstances shown from purchase to accident is adequate to raise an inference that the product was defective and that such condition was causally related to the mishap that occurred. The trial court denied both requests on the ground that they were included in the charge as given.

The matter was submitted to the jury on special interrogatories, the first of which asked whether the jury found "any defect” in the automobile operated by plaintiff Thomas Moraca making it unfit for its intended use which was a proximate cause of the accident. Question three asked whether the jury found that plaintiff Thomas Moraca was eontribu-torily negligent.

After deliberating about two hours the jury returned with the following inquiry:

If the first question is answered “no” hut we also answer question number 3 “no,” can Ford circumstantially be held responsible and Mr. Moraca awarded damages?

Plaintiff’s counsel immediately renewed his request that the jury be told that a manufacturer’s defect can be established by circumstantial evidence and that no specific defect need be identified. The court again denied the requested charge and instead told the jury:

Now, if your answer to that [the first] question is “no” then Ford is not responsible for the accident and there can be no award against Ford; so if you have a situation where you answer question 1 that it is “no,” that is, that there was no defect in the automobile, and your asnwer is also “no” to question number 3, that the plaintiff Mr. Moraca was not guilty of negligence * * *, you still would have no responsibility or no fault on the part of Ford and they cannot be held responsible.

[458]*458Following further deliberation the jury returned a verdict of no cause for action in favor of both defendents by answering “no” to special interrogatories numbered one and three.

The majority opinion of the Appellate Division held that the evidence in the case warranted a charge that circumstantial proof of a defect is sufficient to support a verdict in favor of plaintiff and that the charge as given had not included this concept. We agree.

It is settled in this State that in a products liability case the injured plaintiff is not required to prove a specific manufacturer’s defect. If the proofs permit an inference that the accident was caused by some defect, whether identifiable or not, a jury issue as to liability is presented. Sabloff v. Yamaha Motor Co., Ltd., 59 N. J. 365 (1971). In Scanlon v. General Motors Corp., 65 N. J. 582 (1974), we recently restated the products liability rule as applied to a motor vehicle and said the following about circumstantial proof of a defect, at pp. 592-593:

In addition to the direct evidence device a plaintiff may establish the manufacturer’s responsibility for a defect by means of “other evidence which would permit an inference that a dangerous condition existed prior to sale,” Jakubowski v. Minnesota Mining & Manufacturing, supra, 42 N. J. [177] at 184. Basically, the age and prior usage of the product in relation to its expected life span, durability and effective operability without maintenance are the most important considerations in determining whether an inference is permissible that the defective condition existed prior to sale.

The real question in this case is whether plaintiff’s proofs are sufficient to invoice application of the circumstantial evidence rule. This is essentially a factual determination. Plaintiff Thomas Moraca had purchased the automobile, a 1968 model, new, on November 27, 1967. In February 1968 the car was returned to the dealer for a 6,006 mile checkup. The accident happened on May 28, 1968, at which time the car had been driven about 11,000 miles. Moraca had to take a business trip to Ocean City, Maryland, and decided to drive. Prior to starting out on the trip he stopped at his neighbor[459]*459hood service station for gasoline and a checkup of the front end of his car. The attendant told him his power steering fluid was low and added fluid to the reservoir.

Plaintiff testified that his trip was uneventful until he crossed the Memorial Bridge and headed south on Route 13 in Delaware, a dual highway with two lanes in each direction separated by a 47-foot grass meridian. At the scene of the accident the roadway curved to the right gradually. It had started to rain. While driving in the right hand lane at a speed of about 45-50 miles an hour, plaintiff heard a “gink” in the front of his ear and the steering mechanism suddenly locked and would not respond to plaintiff’s efforts to steer the vehicle which skidded to the right, off the road, across the right shoulder and into a field where it struck a tree.

There was nothing to indicate that the manner of plaintiff’s operation of the vehicle, or the condition of the roadway was a factor in the happening of the accident. Indeed the jury found that the accident was not caused by any negligence on the part of plaintiff. The physical evidence of the accident testified to by the state police officer was that the vehicle left the roadway in a side skid and travelled in a straight line without any turning whatsoever until it struck the tree.

The totality of the evidence and circumstances, if plaintiff’s proofs are credited, tend to negate other possible causes of the accident and indicate that more likely than not a critical malfunction in the steering system occurred.

In Scanlon we cautioned that the older a product is the more difficult it is to prove that a defect existed while in the control of the manufacturer and that the product must be of a type such that a jury, after weighing all of the evidence, would be permitted to infer that, in normal experience, a malfunction would not have occurred at the particular point in the product’s life span had there not been a defect attributable to the manufacturer.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Brian Moleen v. Richard Moleen
New Jersey Superior Court App Division, 2025
Alison Beavan v. Allergan U.S.A., Inc.
New Jersey Superior Court App Division, 2024
VANDEGRIFT v. BIC CORP.
D. New Jersey, 2021
Roskop Dairy v. GEA Farm Tech.
292 Neb. 148 (Nebraska Supreme Court, 2015)
Mendez v. Shah
28 F. Supp. 3d 282 (D. New Jersey, 2014)
Ford Motor Credit Co. v. Mendola
48 A.3d 366 (New Jersey Superior Court App Division, 2012)
Henry v. New Jersey Department of Human Services
9 A.3d 882 (Supreme Court of New Jersey, 2010)
Johnson v. Johnson
9 A.3d 1003 (Supreme Court of New Jersey, 2010)
Schipp Ex Rel. Estate of Neufelder v. General Motors Corp.
443 F. Supp. 2d 1023 (E.D. Arkansas, 2006)
Myrlak v. Port Auth. of NY and NJ
723 A.2d 45 (Supreme Court of New Jersey, 1999)
H.T. Rose Enterprises, Inc. v. Henny Penny Corp.
722 A.2d 587 (New Jersey Superior Court App Division, 1999)
Lewis v. American Cyanamid Co.
715 A.2d 967 (Supreme Court of New Jersey, 1998)
Corcoran v. Sears Roebuck & Co.
711 A.2d 371 (New Jersey Superior Court App Division, 1998)
Sparrow v. La Cachet, Inc.
702 A.2d 503 (New Jersey Superior Court App Division, 1997)
Myrlak v. Port Authority
694 A.2d 575 (New Jersey Superior Court App Division, 1997)
Kass v. Great Coastal Exp., Inc.
676 A.2d 1099 (New Jersey Superior Court App Division, 1996)
Tretina Printing, Inc. v. Fitzpatrick & Associates, Inc.
640 A.2d 788 (Supreme Court of New Jersey, 1994)
Ducko v. Chrysler Motors Corp.
639 A.2d 1204 (Superior Court of Pennsylvania, 1994)
Consalo v. General Motors
609 A.2d 75 (New Jersey Superior Court App Division, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
332 A.2d 599, 66 N.J. 454, 1975 N.J. LEXIS 224, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moraca-v-ford-motor-co-nj-1975.