In Kriegler v. Eichler Homes, Inc. (1969) 269 Cal. App. 2d 224, the court found no difference between the mass production and sale of cars and Eichler's mass production and sale of more than 4,000 residential units.
The Kriegler court noted:
" 'When a vendee buys a development house from an advertised model, as in a Levitt or in a comparable project, he clearly relies on the skill of the developer . . . that the house will be erected in a reasonably workmanlike manner . . . . If there is improper construction such as a defective heating system or a defective ceiling, stairway and the like, the well-being of the vendee and others is seriously endangered and serious injury is foreseeable. The public interest dictates that if such injury does result from the defective construction, its cost should be borne by the responsible developer who created the danger and who is in the better economic position to bear the loss rather than by the injured party who justifiably relied on the developer's skill and implied representation.' " (Id. at p. 228.)