Hills v. Ozark Border Electric Cooperative

MAUS, Judge,

concurring.

I concur in the result. However, I do not believe the liability of the defendant should be analyzed in terms of “strict liability.” I am of the opinion the sale of electricity upon passing through a distribution system such as that in question is not the sale of a “product” within the meaning of 2 Restatement, Law of Torts, Second, § 402A (1965).

A cornerstone of the doctrine of strict liability for product defects is the control of the manufacturer or seller. It has been observed, “[t]he plaintiff must prove (1) that the product was in defective condition when it left the possession or control of the seller....” Ransome v. Wisconsin Elec. Power Co., 87 Wis.2d 605, 275 N.W.2d 641, 647 (1979). “ ‘[T]he manufacturer has the greatest ability to control the risk created by his product since he may initiate or adopt inspection and quality control measures thereby preventing defective products from reaching the consumer.’ ” Ransome, 275 N.W.2d at 647. Without control of the product as delivered, that doctrine should not be applied.

While some cases declare § 402A to be applicable to the sale of electricity through such a distribution system, such cases often have recognized a distinct basis for liability. For example, an uninsulated distribution line in upper branches of a tree frequented by children, Petroski v. Northern Indiana Pub. Service Co., 171 Ind.App. 14, 354 N.E.2d 736 (1976); a failure in distribution line maintenance, Ransome; and failure to lock and seal circuit breakers and to warn, Aversa v. Public Service Elec. & Gas Co., 186 N.J.Super. 130, 451 A.2d 976 (1982).

The inappropriateness of the application of § 402A to such a sale of electricity is demonstrated by the facts of this case. For an undisclosed period of time, the distribution facilities of the defendant had delivered electricity at the proper voltage. Then, apparently because the neutral wire was down, the jury was permitted to find the defendant was liable. This was true irrespective of cause, whether an act of the plaintiffs or a third party, lightning, windstorm, earthquake or a cause not even visualized. In Ransome, it is declared the power company is not an insurer. Yet, liability predicated upon § 402A makes it such.

The generation of electricity in a power plant may be compared to the manufacture of a product. But, there comparison ends. The premise that “[ojrdinarily, electricity leaves the control of the Wisconsin Electric Power Company at the point in the distribution system where a customer’s conductors are connected to the company’s conductors, namely, at the electric meter” is not compatible with reality. Ransome, 275 N.W.2d at 643. Upon leaving the power plant, even though placed in the most perfect distribution system it is possible to *345construct, electricity is no longer within the control of seller. The distinction has been succinctly recognized. “We agree that electricity itself is a product, but conclude that its distribution is a service.” Smith v. Home Light and Power Co., 695 P.2d 788, 789 (Col.App.1984). Section 402A and MAI 25.04 (1981), “Verdict Directing — Strict Liability — Product Defect” are not applicable. Smith v. Home Light and Power Co., supra. Cf. Elgin Airport Inn v. Commonwealth Edison Co., 89 Ill.App.2d 138, 59 Ill.Dec. 675, 432 N.E.2d 259 (1982).

However, I agree that the plaintiffs did not make a submissible case upon the issue of causation. For that reason, the judgment should be reversed.