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Young's MacH. Co. v. Long
Citations: 692 P.2d 24; 100 Nev. 692; 1984 Nev. LEXIS 457Docket: 15160
Court: Nevada Supreme Court; December 7, 1984; Nevada; State Supreme Court
In the case of Young's Machine Company v. Cathy Ann Long, the Nevada Supreme Court addressed an appeal regarding a wrongful death action based on strict products liability. The appellant, Young's Machine Company, sought to have the court recognize comparative fault principles in strict products liability cases, either by interpreting Nevada's comparative negligence statute to apply or by asserting that public policy supports such recognition. The lower court allowed the appellant to argue that the decedent's negligence was the sole cause of death but refused to instruct the jury on using comparative fault to reduce the damages awarded. The Supreme Court affirmed the lower court's judgment, emphasizing that Nevada's comparative negligence statute (NRS 41.141) is intended for negligence actions and does not apply to strict products liability. The court referenced prior decisions (e.g., Davies v. Butler) that similarly declined to extend the statute to other types of claims, indicating a legislative intent to keep strict products liability separate from negligence. It was noted that strict products liability does not require proof of negligence and only allows defenses of assumption of risk or product misuse. The court concluded that the legislature did not intend to include strict products liability within the comparative negligence framework. Appellant argues that the absence of specific legislative guidance on the application of comparative fault in strict products liability cases suggests that courts may adopt such principles. Although the court previously recognized strict products liability in Shoshone Coca-Cola v. Dolinski, it has consistently declined to extend comparative fault principles beyond legislative intent, as seen in several cited cases. Despite some authorities advocating for comparative fault in this context as just, many courts oppose its application in strict products liability. The court concludes that the varied opinions among jurisdictions warrant legislative consideration rather than judicial intervention, emphasizing the need for comprehensive guidelines. The judgment below is affirmed, with justices SPRINGER, MOWBRAY, STEFFEN, and GUNDERSON concurring. The court also clarifies that it does not equate strict products liability with negligence per se, rejecting the stance of certain other courts.