General Motors Corp. v. Sanchez

The principal question in this case is when does the doctrine of comparative responsibility apply in a products-liability case. Relying on its reading of our decision in Keen v. Ashot Ashkelon, Ltd., the court of appeals held that the decedents responsibility for the accident that resulted in his death should not be compared with the manufacturers responsibility because the decedents actions merely amounted to the failure to discover or guard against a product defect. We conclude that: (1) comparative responsibility applies in strict liability if a plaintiffs negligence is something other than the mere failure to discover or guard against a product defect, and (2) there was evidence here the decedent was negligent apart from the mere failure to discover or guard against a product defect. We also conclude that punitive damages may not be awarded in this case because the evidence is legally insufficient to support the finding of gross negligence. Therefore, we reverse the court of appeals judgment and render judgment for the plaintiffs actual damages, as reduced by the jurys comparative responsibility finding.