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General Motors Corp. v. Sanchez | 997 S.W.2d 584 (1999)
Comparative negligence reduces a plaintiff’s recovery by a percentage of the plaintiff’s fault. The doctrine arose in the 1960s in response to the rigidity of contributory negligence, which bars recovery entirely. Only a few states reject comparative negligence today. In General Motors versus Sanchez, we examine the impact of comparative negligence on product liability suits.
The night before Lee Sanchez Junior’s remains were discovered, Sanchez drove his Chevy pickup truck to feed some cattle at a ranch. The next day, a ranch employee found Sanchez’s body pinned between a corral gate and the Chevy’s driver-side door. Sanchez had bled to death. There were no witnesses. The Sanchez family and estate sued General Motors, or GM, arguing that the Chevy’s faulty transmission caused Sanchez’s death.
At trial, the family’s expert posited that Sanchez had stopped his truck to close the corral gate. Sanchez thought he’d shifted the transmission to park but had instead mis-shifted into an intermediate, neutral position. The family argued that the mis-shift resulted from a defect in the design of GM’s gear-shifting mechanism. Once Sanchez exited the Chevy, the faulty gear slipped into reverse, causing the pickup to roll backward. As a result, Sanchez was pinned against the gate. The Chevy’s owner manual was introduced into evidence. The manual stated that drivers should take a number of precautions to ensure safe parking, including shifting to the furthest position, turning the vehicle off and removing the key, and double-checking the gear position by pulling the gear shift down. The family posited that Sanchez would’ve read the manual. In addition, the family’s expert conceded that Sanchez hadn’t followed the listed precautions and that heeding a single precaution would’ve prevented the accident.
A jury returned a verdict for the family, finding GM strictly liable for the transmission design defect and Sanchez 50 percent responsible for the fatal injury. The trial judge instructed the jury to ignore comparative negligence for damage calculations, and the jury awarded eight and a half million dollars to the family. GM appealed. The court of appeals affirmed, so GM appealed to the Texas Supreme Court.
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