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Helen Henningsen Case

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Plaintiff Claus H. Henningsen purchased a car manufactured by defendant Chrysler Corporation, from defendant Bloomfield Motors, Inc. His wife, plaintiff Helen Henningsen, was injured while driving it and filed suit against defendants to recover damages. The action was based on breach of express and implied warranties as well as negligence. The reverse side of the contract contained much fine print including the warranty, which stated in part: “It is expressly agreed that there are no warranties, express or implied, made by either the dealer or the manufacturer on the motor vehicle...except as follows: The manufacturer warrants...vehicle...to be free from defects in material or workmanship...Its obligation under this warranty being limited…show more content…
Defendants appealed. ISSUE: Are defendants bound by an implied warranty of merchantability, despite disclaimer? RULING: Yes. Judgments against defendants were affirmed. RATIONALE: Ordinarily in a sale of goods there is an implied warranty of merchantability, which means that the item is reasonably fit for the general purpose for which it was manufactured and sold. For implied warranties, the Uniform Sales Act imposed obligations on the the seller as a matter of law, and thus did not depend upon any express agreement of the parties. Accordingly, the court held that when a manufacturer puts a new car in the stream of commerce, an implied warranty accompanies the car to the ultimate purchaser. Although the express warranty in this case intended to limit the manufacturer's liability to replacement of defective parts, and disclaimed all other express or implied warranties, the court believed that such rules could not be applied on a strict basis. The conflicting interests of the parties must be considered, along with social policy. Warranties originated to protect the buyer, not to limit the liability of the seller. The court felt that the motive of the manufacturer in this case was to avoid the warranty obligations normally incidental to these
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