Caterpillar Tractor Co. v. Beck
Alaska Supreme Court
593 P.2d 871 (1979)
- Written by Kate Luck, JD
Facts
Derald Allen Beck was driving a front-end loader manufactured by Caterpillar Tractor Co. (Caterpillar) (defendant) when the loader sank into the ground along the side of the road, rolled over, and fell down an embankment. Beck was crushed to death in the accident. The loader had an overhead canopy, but it was not designed to protect the driver if the loader rolled. Beck’s wife (plaintiff) sued Caterpillar for wrongful death, alleging that the loader was defectively designed without a rollover-protective shield. It was undisputed at trial that a rollover-protective shield would have saved Beck’s life. The trial court instructed the jury that if a product fails to incorporate a design feature and injury results, the product is defective. The jury returned a verdict for Beck’s wife, and the trial court entered judgment accordingly. Caterpillar appealed, arguing that the trial court erred by improperly instructing the jury on strict liability for design defects, essentially imposing absolute liability. Caterpillar also argued that the court should have defined design defect for the jury, and Beck’s wife argued that design defect had an inherent meaning.
Rule of Law
Issue
Holding and Reasoning (Connor, J.)
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