Lee v. Electric Motor Division

In Lee v. Electric Motor Division (1985) 169 Cal.App.3d 375, plaintiffs sued after Mrs. Lee's hand became caught in a meat grinder and was crushed. Defendant designed, manufactured and sold the motor that was incorporated into the meat grinder, which was designed, manufactured and sold by Lasar Manufacturing Company. The summary judgment granted in favor of defendant was affirmed. Plaintiff contended the motor was defectively designed because it could have been built to stop immediately when it was turned off by attaching a brake or clutch, and if it had stopped immediately her injuries would have been less severe. The evidence submitted showed Lasar designed the meat grinder without any participation by defendant; Lasar ordered the motor it wanted from defendant without asking defendant's advice. (Id. at pp. 384-385.) The motor was a standard shelf item. (Id. at p. 387.) The court noted: "We have found no case in which a component part manufacturer who had no role in designing the finished product and who supplied a nondefective component part, was held liable for the defective design of the finished product. To the contrary, the cases relied on by defendant demonstrate a reluctance against imposing liability in this situation." (Id. at p. 385.) Regarding plaintiff's allegation of failure to warn, the court stated: "There is nothing to indicate that the motor in its use had unreasonably dangerous propensities not ordinarily discoverable by the user. The uncontradicted evidence shows that all motors, even 'brake motors,' do not stop immediately. There is no danger in the motor which would not have been obvious to a person of ordinary intelligence." (Lee, supra, 169 Cal.App.3d at p. 388.)