Wangen v. Ford Motor Company
Wisconsin Supreme Court
97 Wis. 2d 260 (1980)
A Ford Mustang's fuel tank ruptured and caused a fatal fire after a collision; the plaintiffs alleged Ford knew of the defect causing the fire but concealed it rather than incurring the expense and negative publicity of a recall, and sought punitive damages on a products-liability theory. Ford moved to dismiss, arguing punitive damages require intentional tortious conduct and citing multiple policy objections to allowing them in strict-liability or negligence-based product cases; the trial court denied the motion.
Whether punitive damages are available in a products-liability case based on strict liability or negligence if the defendant's conduct showed reckless disregard of others' rights or interests.