Rix v. General Motors Corp.

Facts

Michael Rix (plaintiff) was driving his pickup truck when he was hit from behind by a General Motors Corp. (“GMC”) (defendant) two ton chassis-cab. The two ton chassis-cab had been equipped with a water tank after its sale. Rix suffered injuries as a result of the accident. He sued GMC on a theory of strict liability. Rix alleged that the two ton-chassis cab was an unreasonably dangerous product because of both manufacturing and design defects. Rix further alleged that GMC was strictly liable because the company had placed the product into the stream of commerce. GMC stipulated that the accident occurred because of a brake failure resulting from a defective brake tube. However, GMC also contended that the defect was not present when the product left the assembly line. The defect was instead introduced by someone else who later altered the product. Therefore, GMC claimed that the defective tube was not the company’s responsibility. The jury was instructed that, in order to make a finding of strict liability, they would have to find: (1) that GMC sold a dangerous product, (2) that the product reached the consumer without substantial change in its condition, and (3) that the defective condition proximately caused the injury to plaintiff. The jury returned a verdict in favor of GMC. Rix appealed to the Supreme Court of Montana, alleging that improper instructions were given to the jury. Namely, Rix argued that the jury instructions improperly stated Montana’s law regarding the tracing requirement back to GMC.