Campos v. Firestone Tire & Rubber Co.

In 1971, Armando Campos (plaintiff), a Portuguese immigrant, began working assembling tires at a truck-trailer manufacturer, Theurer Atlantic, Inc. (Theurer). Campos placed rubber tires on a rim consisting of three assembled parts then placed the tire into a Theurer-made steel safety cage designed to contain the parts in case they separated while being inflated with an air hose. Unable to read or write, Campos received oral instructions on the need to place the tire in the cage before inflating it. In 1972, Campos was injured when he placed his hand in the cage during tire inflation to prevent a mishap. In 1978, as he inflated a tire, Campos noticed that a locking element on the rim components was opening. Fearing a fatal accident if the parts blew apart, Campos tried to disengage the air hose by reaching into the cage. The rim assembly exploded, severely injuring Campos. Campos sued the rim-assembly manufacturer, Firestone Tire & Rubber Company (Firestone) (defendant), alleging two strict-liability theories, improper design and failure to warn. Firestone had provided manuals, including a large, government-prepared chart that Theurer posted. The chart described in writing the need for a cage and to stand clear while inflating. Campos’s expert said a pictorial warning should have been included. The expert also testified that a warning might not have suppressed Campos’s instinctive placing of his hand in the cage. The jury was charged with determining whether a failure to warn was a proximate cause of the injury, but not the role Campos’s prior knowledge played in the accident. The jury returned a verdict of $255,000. Firestone appealed. The appellate division reversed. The New Jersey Supreme Court granted certification.