Analysis: Review of Washington Supreme Court decisions

In 1969, the Washington Supreme Court, after extensive review of product liability cases beginning in 1913, adopted the strict liability contained in § 402A as the law of this jurisdiction. Ulmer, 75 Wn.2d 522, 531-32. That decision applied only to the liability of manufacturers.

In 1975, the Washington Supreme Court after further review of product liability cases, extended § 402A strict liability to those in the business of selling or distributing a product. Tabert, 86 Wn.2d 145, 148-49. Both Ulmer and Tabert were remanded for trial with instructions to apply the strict liability rules announced in the appellate decision. Ulmer, 75 Wn.2d at 532; Tabert, 86 Wn.2d at 155-56.