Binakonsky v. Ford Motor Co.

United States District Court for the District of Maryland · Torts

Tortsproducts liabilitystrict liabilitycrashworthinessdesign defectsummary judgmentsecond collisionenhanced injury

Facts

David Binakonsky drove his 1988 Ford E-150 van, while intoxicated and on a revoked license, off the road at more than forty miles per hour and head-on into a large tree. The impact drove the engine rearward into the passenger compartment, gasoline ignited, and the decedent died from thermal injuries after suffering fourth-degree burns over his entire body. Plaintiffs alleged that the van's fuel injection lines, connectors, shut-off switch, engine placement, passenger-compartment configuration, and front doors were defectively designed, causing enhanced fatal injuries after the initial collision. The van was a relatively inexpensive cargo-type van designed to maximize interior space by placing the driver's seat forward and the engine partly within the passenger compartment under a removable doghouse cover.

Issue

Under Maryland law, may plaintiffs proceed on strict liability crashworthiness claims alleging that the Ford E-150's design was defectively dangerous where the decedent, while intoxicated, drove the van at high speed into a tree and the collision caused a fatal fire? More specifically, does Maryland permit such strict liability design-defect claims, and if so, was this van's design unreasonably dangerous as a matter of law under the circumstances of this crash?

Rule

Maryland permits a strict liability cause of action for an alleged motor vehicle design defect in a crashworthiness case, and contributory negligence is not a defense to a products liability suit based on strict liability. But in crashworthiness design-defect cases, the inquiry into whether a product is unreasonably dangerous is essentially the same as the negligence reasonableness inquiry: the court must assess whether the manufacturer could reasonably foresee that the challenged design would subject users to unreasonable risk in the type of collision at issue, balancing the likelihood and gravity of harm against the burden of effective precautions, while considering the vehicle's style, type, purpose, price, and the nature and severity of the accident.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Maryland, Nora Patel was driving a delivery van made by Harbor Trail Vehicles in Baltimore when she sped through a red light and struck a guardrail. She suffered severe burns after the van's allegedly defective fuel-line routing caused a post-impact fire, and she sues the manufacturer only on a strict liability crashworthiness theory for enhanced injuries.

Harbor Trail argues that Nora's own negligent driving bars recovery under Maryland contributory negligence rules. How should the court rule?

Explanation. The majority opinion recognizes that Maryland allows a strict liability cause of action for alleged motor-vehicle design defects in crashworthiness cases, and it states that contributory negligence is not available as a defense to a products-liability suit based on strict liability. Although the plaintiff's conduct may still be relevant to the design-reasonableness analysis, it does not operate as a complete bar the way it would in negligence. (Derived from Binakonsky v. Ford Motor Co. (n.d.).)