Kaneko v. Hilo Coast Processing
Supreme Court of the State of Hawai'i
654 P.2d 343 (1982)
Ironworker Milton Kaneko (plaintiff) was injured when a steel girt he was standing on gave way because it hadn't been fully welded. He sued the girt's manufacturer, Hilo Coast Processing (defendant), for negligence, breach of warranty, and strict products liability, and the jury found in his favor, but the trial court reduced the award in proportion to Kaneko's own contributory negligence. On cross-appeal, Hilo challenged the strict-liability finding while Kaneko argued that contributory negligence should never reduce a strict-liability award at all.
Whether comparative negligence may be merged with strict products liability so that damages awarded against a manufacturer can be reduced in proportion to the consumer's own contributory negligence.