A recent California appeals court decision upheld a $24.7 million verdict after a rear-end collision left the driver a paraplegic when her car seat that was built by Johnston Controls collapsed. The court also remanded the case for a retrial on the allocation of damages, ruling that a seat designer could not be held liable for a product it did not manufacture.
The plaintiff’s suit accused a number of car seat manufacturers and designers alleging design defects in the seat of her Nissan Frontier pickup truck. In the court’s opinion, Ikeda Engineering Corporation, which helped design the seat, could not be subject to strict product liability because it did not bring the seat to market. The court remanded the suit for retrial on the single issue of apportioning fault among manufacturers. The retrial is limited to damages allocation, and not a liability. “Ikeda may be found at fault for plaintiff’s injuries and assigned a proportionate share of plaintiff’s noneconomic damages, but not on a strict products liability theory,” the panel ruled. The panel upheld the amount of the verdict in the driver’s favor, ruling that she showed enough evidence to support her theory that the product did not perform as safely as an ordinary consumer would expect. The defendants had argued against this consumer expectations theory, saying it does not apply in the case of complex technical issues involving automobiles, according to the opinion. But the panel disagreed that the problem with her car seat amounted to such a complex matter. The suit named several defendants, including Nissan Motor Co. Ltd. and its affiliates, Vintec Co., which manufactured the seat, and Ikeda Engineering, the designer of the seat.
Automotive seating and car interior electronics maker Johnson Controls Inc., which was the successor in interest to Vintec and Ikeda, agreed to be legally responsible to pay the damages awarded against Vintec or Ikeda.
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