Armstrong Rubber Co. v. Urquidez
This appeal addresses whether strict liability in tort applies when a product, a "non-interest spare" tire, has not entered the stream of commerce but was provided by the manufacturer, Armstrong Rubber Company, to Automotive Proving Grounds, Inc. for mutual benefit testing of other tires. Clemente Urquidez, a test driver, was killed due to a blowout of this tire. The trial court and Court of Civil Appeals found the tire defective and applied strict liability. The Supreme Court of Texas reversed, holding that the strict liability doctrine, as adopted in Texas, requires the product to be placed in the stream of commerce. Since the defective tire was manufactured and used solely within an industrial testing process and never released to the consuming public, the doctrine of strict liability was deemed inapplicable.