Article: Rolling the "barrel" a little further: allowing res ipsa loquitur to assist in proving strict liability in tort manufacturing defects.

In England in 1863, a barrel of flour rolled out of the second floor of a barn, struck a passerby walking underneath, and, as William Prosser said, rolled "into the lives of all tort lawyers."(1) Faced with this wayward barrel, the English court crafted the now-famous tort doctrine of res ipsa loquitur.(2) The court held that the peculiar circumstances of the accident generated a presumption of negligence, allowing recovery even though the plaintiff could not prove negligence directly.(3) One hundred years later, Chief Justice Traynor of the California Supreme Court ushered in a new liability scheme, holding a manufacturer of a power tool strictly liable in tort for a ...

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