Uniroyal Goodrich Tire Co. v. Martinez
977 S.W.2d 328 (Tex. 1998)

Facts:

  • Martinez suffered injuries when he was struck by an exploding 16” Goodrich tire that he was mounting on a 16.5” rim. Attached to the tire were a number prominent and conspicuous warnings.
  • A products liability suit was brought for defective design.
  • Martinez’s expert testified that a 0.050 gauge single strand programmed bead should’ve been used instead of a 0.037 gauge multi-strand weftless bead.
    • It is stronger and more resistant and would’ve prevented the injuries.
    • Additionally, they were widely available (Goodyear, Yokohama, General Tire, and even Goodrich itself were using them).

History:

  • Trial court jury ruled in favor of Martinez.
  • Court of Appeals affirmed.

Issue:
Whether a manufacturer who knew of a safer alternative product design is liable in strict products liability for injuries caused by the use of its product that the user could have avoided by following the product’s warnings.

Holding:
Yes. Affirmed.

Reasoning:

  • Defendants unsuccessfully argued Restatement (Second) of Torts § 402A cmt. j:
    • “ Where warning is given, the seller may reasonably assume that it will be read and heeded; and a product bearing such a warning, which is safe for use if it is followed, is not in defective condition, nor is it unreasonably dangerous.”
  • The court, however, found that Restatement (Third) of Torts § 2 cmt. L: expressly rejected that approach:
    • “…when a safer design can reasonably be implemented and risks can reasonably be designed out of a product, adoption of the safer design is required over a warning that leaves a significant residuum of such risks. Compare Comment e. Warnings are not, however, a substitute for the provision of a reasonably safe design.
  • “We agree with the new Restatement that warnings and safer alternative designs are factors, among others, for the jury to consider in determining whether the product as designed is reasonably safe.”

Rule: Even though a plaintiff’s injuries could have been avoided by following a product’s warnings, manufacturers who know of safer alternative product designs may be strictly liable.

Rule: Warnings and safer alternative designs are factors, among others, for the jury to consider in determining whether a product as designed is reasonably safe.