Calhoun v. Honda Motor Company
United States Court of Appeals for the Sixth Circuit
738 F.2d 126 (1984)
Calhoun (plaintiff) crashed his motorcycle after washing it, driving several miles with intervening stops, and parking it for 20 minutes, then sued Honda (defendant) for strict products liability based on a recall addressing wet-weather brake performance. Calhoun's expert, Klein, opined the brakes were wet and caused the crash, but admitted he didn't account for the distance traveled, number of stops, brake-pad material, or drying time, and conceded he had no way of knowing whether the accident was actually caused by wet brakes or Calhoun's own failure to react, and that the skid marks were consistent with perfectly dry brakes too. The jury found for Calhoun, but the trial judge entered judgment for Honda, ruling Klein's opinion lacked a factual basis, and Calhoun appealed.
Whether a strict products liability claim requires proof that the alleged product defect actually caused the plaintiff's injury.