Eastwood v. Horse Harbor Foundation, Inc., 170 Wash. 2d 380 (2010)

Citation: Eastwood v. Horse Harbor Foundation, Inc., 170 Wash. 2d 380 (2010)
Parent Document: Eastwood v. Horse Harbor Foundation, Inc., 170 Wash. 2d 380 (2010)
Jurisdiction: Washington (state)
Effective Date: 2010-11-04
Original Source: https://www.courtlistener.com/opinion/4909141/eastwood-v-horse-harbor-foundation-inc/ ↗

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¶27 But the Court did not simplistically rest its holding on its finding that the plaintiffs’ losses were economic losses. Although the law of contracts applied, the Court also inquired whether there was a tort duty independent of any contractual terms. As a policy matter, the Court preferred warranty law’s “built-in limitation on liability” and sought to protect a manufacturer from worrying about “the expectations of persons downstream who may encounter its product.” Id. at 874. Based on these considerations, the Court “h[e]ld that a manufacturer in a commercial relationship has no duty under either a negligence or a strict products-liability theory to prevent a product from injuring itself.” Id. at 871.

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