Can a plaintiff sue the manufacturer of a product which, if negligently made, causes injury to person or property?

A similar issue was addressed in Fentress v. Van Etta Motors (1958) 157 Cal.App.2d Supp. 863, 323 P.2d 227; where the trial court had sustained a general demurrer to plaintiff's complaint seeking recovery for damages to his car caused by a crash resulting from negligently manufactured brakes. The court asked, "Will an action lie against the manufacturer of an article which, if negligently made, is likely to produce injury to person or property, for damages resulting from an accident caused by the negligence, where the [158 Cal.App.3d 299] damages are confined to destruction or harm to the article itself?" (Id., at p. 864, 323 P.2d 227.) The Fentress court answered yes, with four conditions: (1) negligence must be proved; (2) the product must be of the type which, if not manufactured correctly, is reasonably certain to cause harm to persons or property; (3) an accident must have resulted; and (4) "the accident must be a casualty involving some violence or collision with external objects, not a mere marked deterioration, or even a complete ruin brought about by internal defect." (Id., at pp. 865-866, 323 P.2d 227, disapproved on another point in Sabella v. Wisler (1963) 59 Cal.2d 21, 29-30, 27 Cal.Rptr. 689, 377 P.2d 889.) ⁵