Waters-Pierce Oil Co. v. Deselms

Background

A grocer’s clerk, Deselms, sued an oil company after his wife and two young children died when their home exploded. The family had purchased what they thought was coal oil from a local grocer; unknown to them, the oil company had mixed gasoline into a coal oil tank and sold the product without reinspection or the required safety branding. Territory law required inspection, testing, and labeling of oils and gasoline, and the oil company charged an inspection fee though the barrels lacked proper marks.

Reasoning

The Court examined whether the oil company acted wrongfully and whether the evidence justified a jury trial. Experts and eyewitnesses showed the mixture was highly inflammable (a small percentage of gasoline lowered the flash point) and the lamp and a bottled sample behaved dangerously. The jury was instructed that coal oil was commonly used for kindling fires and that the oil company knew its product would be used that way. The Court found sufficient evidence to let the jury decide and affirmed the verdict that the company unlawfully sold a dangerous mixture and was liable for the deaths. The Court also rejected arguments that the territorial inspection law was invalid due to awkward wording.

Real world impact

This decision leaves intact a jury’s power to hold a fuel seller responsible when it puts unsafe, mislabeled petroleum products on the market. It confirms that community customs about household fuel use matter to liability, and it upholds the territorial inspection rules intended to protect buyers.