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Larsen v. General Motors Corporation
United States Court of Appeals for the Eighth Circuit
391 F.2d 495 (1968)
Erling David Larsen (plaintiff) was in a head-on collision while driving a Corvair manufactured by General Motors Corporation (GM) (defendant). The impact occurred on the left-front corner of the Corvair, causing the steering mechanism to thrust into Larsen’s head. Larsen sued GM for design defect, alleging negligence in the design of the steering assembly. Larsen did not claim that the design caused the accident, but rather that because of the design he sustained injuries he would not have otherwise sustained or that his injuries would have been less severe. The rearward displacement of the steering shaft was much greater on the Corvair than it would have been in other cars designed to protect against such a rearward displacement. GM argued it had no duty of care in designing an automobile to make it safer in a collision or to make it accident-proof, and therefore it could not be negligent for failure to design either a safe car or a safer car. Larsen argued that GM had a duty to use reasonable care in designing the Corvair to make it safe to the user for its foreseeable use and that the Corvair’s intended use or purpose was driving on streets and highways, which included the possibility of colliding with other vehicles or stationary objects. The trial court held that GM did not have a duty to make a vehicle that would protect Larsen during a head-on collision and rendered summary judgment for GM.
Rule of Law
Holding and Reasoning (Gibson, J.)
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