Henningsen v. Bloomfield Motors

Mr. Henningsen wanted to buy his wife a car for Mother's Day. They visited a Chrysler dealer, Bloomfield Motors, Inc. ("Bloomfield") & selected a 1955 Plymouth sedan.

The purchase contract was an integrated contract stating "No express or implied warranties are made on the vehicle."

10 days after the car purchase, Mrs. Henningsen was driving at 20 mi/h. All of a sudden, she heard a loud crack from under the car, the steering wheel jerked in her hands, the car spun off the road, & crashed into a brick wall.

The Henningsens sued Bloomfield & Chrysler claiming breached express & implied warranty after their car was totaled.

Henningsens won in the trial court.

Does a manufacturer that offers a product for sale & engages in promotional activities to entice buyers incurs an implied warranty obligation in relation to that product?

Yes. A manufacturer that offers a product for sale & advertises it to the public incurs an implied warranty that the product is reasonably suitable for its advertised use.

Court: A disclaimed warranty by a manufacturer is contrary to public welfare.

Court: A manufacturer's obligation to a buyer shouldn't be based on privity of contract.

This decision is a deviation from traditional contract law. The plaintiff prevailed in this case despite having signed a contract agreeing to relinquish express & implied warranties.

American courts now stipulate implied warranty for new car purchases.