Madonna v. Harley Davidson, Inc.
Superior Court of Pennsylvania
708 A.2d 507 (1998)
Charles Madonna (plaintiff), whose Harley Davidson, Inc. (Harley) (defendant) motorcycle contained a defective brake-caliper bolt, crashed while having a 0.14 percent blood-alcohol level; Madonna and passenger Delores Wilson (plaintiff) sued Harley on a strict-liability products claim, and Harley presented evidence the bolt was functioning properly at the time of the crash and that Madonna's intoxication was the sole cause of the accident. The trial court ruled for Harley, and Madonna appealed, arguing plaintiff conduct is irrelevant in a strict-liability products case.
Whether, if the defense in a products-liability case presents evidence to establish that the plaintiff's injury was solely the result of the plaintiff's conduct, and not related in any way to a product defect, that evidence is relevant to prove causation.