Extraordinary, Chief Justice Traynor revolutionized American product liability law through his influential concurring opinion in Escola v. Coca-Cola (Escola). Justice Traynor’s’ concurring opinion in Escola argues for affirmance of the jury award of damages in the case on the grounds of strict liability rather than negligence. The concurring opinion made a “difference and laid the groundwork” for our modern legal rules of product liability.
Previous cases and other legal devices prior to Escola display and develop the procedure of product liability law. The legal devices used in product liability law that are essential in Escola are the application of res ipsa loquitur and negligence, which were primarily used prior to Justice Traynor concurring …show more content…
Boadle is a non-manufacturing case establishing precedence of res ipsa loquitur prior to Escola. The plaintiff, Byrne, was walking on a public street past the defendant’s, Boadle, shop when a barrel of flour fell upon him from a window above the shop, and seriously injured the plaintiff. The plaintiff could not prove direct evidence whether the defendant is responsible for his injuries. The court of Byrne established circumstantial evidence to be enough to prove the defendant is liable based on a reasonable person would believe a barrel of flour does not ordinary fall from a shop (GRAD RESOURCE Byrne v Boadle Pg. 1-3).
In both MacPherson and Byrne demonstrates how negligent and re ipsa are essential in the application of product liability law. Prior to Escola, Manufacturers were held liable for negligence and re ipsa instead of strict liability. Before strict liability, the manufacturers benefited more than the injured due to they were not capable of proving manufacturers negligence (GRAD RESOURCE Dillion v. Legg Pg.1). Fortunately, Justice Traynor influence of strict liability helped the injured parties no longer bear the burden of proving …show more content…
Analysis of Escola Supreme Court
The Supreme Court analyzes Belli’s application of re ipsa loquitur and affirmed the original decision of the trial court of Escola in favor of plaintiff, (Escola S. Ct. Opinion Pg.8-9). The Supreme Court applied the requirements of the legal rule of res ipsa. The Supreme Court has described the proper use of “re ipsa loquitur” does not apply unless defendant had exclusive control of things causing the injury and the accident is such a nature that it ordinarily would not occur in the absence of negligence by the defendant (Escola Ct. of Appeals Pgs. 4-6).
The defendants had control at the time of the negligent act but not at the time of the incident, due it the instrumentality left the defendants possession (GRAD RESOURCE Ybarra v Spangard). The plaintiff’s injuries can be traced back to the manufacturer when the product reached in the market; nevertheless, the manufacturer is held liable (GRAD RESOURCE Li v. Yellow Cab Co.) Also, the defendants are considered independent “tortfeasor” thus each defendant is liable for damages caused by him alone due to its impossible to prove whose conduct actually caused the harm (GRAD RESOURCE Summer v.
Previous cases and other legal devices prior to Escola display and develop the procedure of product liability law. The legal devices used in product liability law that are essential in Escola are the application of res ipsa loquitur and negligence, which were primarily used prior to Justice Traynor concurring …show more content…
Boadle is a non-manufacturing case establishing precedence of res ipsa loquitur prior to Escola. The plaintiff, Byrne, was walking on a public street past the defendant’s, Boadle, shop when a barrel of flour fell upon him from a window above the shop, and seriously injured the plaintiff. The plaintiff could not prove direct evidence whether the defendant is responsible for his injuries. The court of Byrne established circumstantial evidence to be enough to prove the defendant is liable based on a reasonable person would believe a barrel of flour does not ordinary fall from a shop (GRAD RESOURCE Byrne v Boadle Pg. 1-3).
In both MacPherson and Byrne demonstrates how negligent and re ipsa are essential in the application of product liability law. Prior to Escola, Manufacturers were held liable for negligence and re ipsa instead of strict liability. Before strict liability, the manufacturers benefited more than the injured due to they were not capable of proving manufacturers negligence (GRAD RESOURCE Dillion v. Legg Pg.1). Fortunately, Justice Traynor influence of strict liability helped the injured parties no longer bear the burden of proving …show more content…
Analysis of Escola Supreme Court
The Supreme Court analyzes Belli’s application of re ipsa loquitur and affirmed the original decision of the trial court of Escola in favor of plaintiff, (Escola S. Ct. Opinion Pg.8-9). The Supreme Court applied the requirements of the legal rule of res ipsa. The Supreme Court has described the proper use of “re ipsa loquitur” does not apply unless defendant had exclusive control of things causing the injury and the accident is such a nature that it ordinarily would not occur in the absence of negligence by the defendant (Escola Ct. of Appeals Pgs. 4-6).
The defendants had control at the time of the negligent act but not at the time of the incident, due it the instrumentality left the defendants possession (GRAD RESOURCE Ybarra v Spangard). The plaintiff’s injuries can be traced back to the manufacturer when the product reached in the market; nevertheless, the manufacturer is held liable (GRAD RESOURCE Li v. Yellow Cab Co.) Also, the defendants are considered independent “tortfeasor” thus each defendant is liable for damages caused by him alone due to its impossible to prove whose conduct actually caused the harm (GRAD RESOURCE Summer v.