Tn Farmers Mutual vs. Ford Motor

This is a consolidated appeal of three products liability cases. Three vehicles manufactured by the defendant automobile company were destroyed by spontaneous combustion, allegedly caused by a defective steering column. No personal injuries resulted from the fires, and no other property was damaged. The plaintiff insurance company, which insured the cars, paid the owners the value of the vehicles. The insurance company, as subrogee for the insureds, then filed the actions below, seeking to recoup the payments from the defendant automobile manufacturer to the insureds on a theory of products liability. The trial court dismissed the actions, holding that the economic loss doctrine precluded recovery in tort, because the product damaged only itself in each case. The plaintiff insurance company now appeals. The appeals were consolidated for purposes of our review. We affirm the trial court in all respects, finding that the economic loss doctrine precludes recovery in these cases.