Greenman v. Yuba Power Products

IRAC Summary of Greenman v. Yuba Power Products, Inc.

Issue: The primary issue in Greenman v. Yuba Power Products, Inc. is whether a manufacturer can be held strictly liable in tort when a consumer is injured by a defective product, even in the absence of a contract between the injured party and the manufacturer.

Rule: The rule established in this case is that a manufacturer is strictly liable in tort when an article he places on the market, knowing that it is to be used without inspection for defects, proves to have a defect that causes injury to a human being.

Application: Greenman received a Shopsmith as a gift, which was a combination power tool that could be used as a saw, drill, and wood lathe. He was injured when a piece of wood he was shaping on the Shopsmith flew out and struck him on the head. He claimed the injury occurred because of a defect in the design and manufacture of the Shopsmith and that Yuba Power Products had breached implied warranties. There was no direct contractual relationship between Greenman and Yuba Power Products.

Conclusion: The court concluded that Yuba Power Products, Inc. could be held strictly liable in tort for injuries caused by defects in its product, despite the absence of a contract with the injured party, because it placed the product on the market expecting it to reach consumers without alteration.

Detailed IRAC Outline of Greenman v. Yuba Power Products, Inc.


The detailed issue is whether Yuba Power Products, Inc. can be held liable for the plaintiff’s injuries caused by an alleged defect in a product, the Shopsmith, where the plaintiff did not purchase the product from the defendant but received it as a gift, thus raising questions about the application of strict liability in tort without privity of contract.


The legal principles that guide the decision include:

  1. The doctrine of strict liability in tort, which holds a manufacturer accountable for product defects that cause injury, regardless of privity of contract.
  2. Precedent set by previous cases that had begun to establish the responsibility of manufacturers for harm caused by defective products, moving away from the necessity of a direct contractual relationship.


A detailed analysis of the application of these rules to the case:

  1. Examination of the facts surrounding the injury, including the manner in which Greenman used the Shopsmith and the nature of the accident.
  2. The court’s evaluation of expert testimony and evidence regarding the alleged defect in the Shopsmith, including manufacturing and design considerations.
  3. The court’s review of the implied warranties and whether they were breached.
  4. The argument that the lack of warning contributed to the injury, which further supports strict liability in the absence of negligence.
  5. The analysis of whether a direct contract or sale was necessary for liability or whether placing the product into the stream of commerce was sufficient.
  6. The impact of public policy considerations on the court’s decision, particularly the protection of consumers from unsafe products and the allocation of loss to manufacturers who are better positioned to absorb the costs.


The court’s final judgment in Greenman v. Yuba Power Products, Inc. rests on the establishment of strict liability in tort for manufacturers. The ruling emphasizes that a manufacturer that sells a product in a condition that is dangerous to the user or consumer, without warning, is liable for any injury caused by the product’s defect. The conclusion sets a significant precedent for product liability and consumer protection, marking a shift away from the necessity of privity of contract in such cases.

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