In Vern J. Oja Associates v. Washington Park Towers, Inc., 89 Wash. 2d 72, 569 P.2d 1141 (1977), the Supreme Court of Washington held that pile driving was abnormally dangerous.
In that case, a jury returned a verdict of $ 73,100 for damage to an apartment building.
The defendant engaged in pile driving in order to construct a condominium tower on the adjacent lot.
The Supreme Court of Washington, applying section 520 of the Restatement (Second) of Torts (1977), held that the trial court did not err in submitting the strict liability count to the jury.
Without extended analysis, the Washington court concluded:
"In the past, this court has found strict liability where damage was caused to plaintiff's well as the result of vibrations caused by an explosion. We find no significant distinction between vibrations caused by an explosion and vibrations caused by pile driving." Vern J. Oja Associates, 569 P.2d at 1143.