Garcia v. Tex. Instruments, Inc

In Garcia v. Tex. Instruments, Inc., 610 S.W.2d 456, 463-64 (Tex. 1980), Garcia suffered severe acid burns when he tripped at work while carrying containers of concentrated sulphuric acid. 610 S.W.2d at 457. Garcia's employer purchased the sulphuric acid from Texas Instruments. Id. Garcia sued Texas Instruments alleging breach of the implied warranty of merchantability. Id. The supreme court concluded that, through Garcia's employer, there was a relationship between the non-purchasing employee who was affected by the product and Texas Instruments. See id. at 463-65. The Court reasoned that: "there is no adequate rationale or theoretical explanation why non-users and non-consumers should be denied recovery against the manufacturer of a defective product. The reason for extending the strict liability doctrine to innocent bystanders is the desire to minimize risks of personal injury and/or property damage. A manufacturer who places in commerce a product rendered dangerous to life or limb by reason of some defect is strictly liable in tort to one who sustains injury because of the defective condition. . . ." (Id. at 465.) In Garcia, the supreme court held that "privity of contract is not a requirement for a uniform-commercial-code-implied-warranty action for personal injuries." Id.