Jahn v. Hyundai Motor Co.

Iowa Supreme Court · Torts

TortsProducts liabilityEnhanced injuryComparative faultJoint and several liabilityenhanced injurycrashworthinessproducts liability

Facts

Grace Burke drove through a stop sign in Clinton, Iowa and struck Glen Jahn's Hyundai Elantra. After the impact, the driver-side front airbag allegedly failed to deploy, and Jahn suffered multiple serious injuries. Before suing Hyundai Motor America, Jahn settled with Burke and her insurer, making Burke a released party under the Iowa Comparative Fault Act. The Jahns then sued Hyundai, alleging the airbag defect caused enhanced injuries that would have been avoided absent the defect.

Issue

In an enhanced injury products liability case, should Iowa adopt Restatement (Third) of Torts: Products Liability §§ 16 and 17, including the Fox-Mitchell approach to indivisible injuries, comparative fault, and joint and several liability? Also, may the jury compare the fault of a released party whose negligence proximately caused the underlying accident and the plaintiff's injuries when deciding the enhanced injury claim against the manufacturer?

Rule

In an enhanced injury case, the plaintiff must prove the fact of enhanced injury by offering evidence that the design defect was a substantial cause of injury above and beyond what would have occurred without the defect; the plaintiff need not prove a divisible injury. If the proof supports determination of the harm that would have occurred absent the defect, the manufacturer is liable only for the increased harm; if proof does not support that determination, the manufacturer may be liable for all harm attributable to the defect and other causes. Iowa Code chapter 668 applies to enhanced injury cases, so comparative fault, comparison of released parties, and joint and several liability principles govern allocation of responsibility.

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

In Des Moines, Nora Ellison was riding in a sedan when Owen Price ran a red light and struck the car. Nora sues Prairie Vista Autos, alleging the seatbelt buckle was defectively designed and unlatched during the collision, worsening her abdominal and spinal injuries. Her experts can say the buckle failure substantially increased her injuries beyond those caused by the crash itself, but they cannot quantify the precise increment.

Under the governing rule, has Nora produced enough on causation to submit her enhanced injury claim to the jury?

Explanation. The plaintiff's burden in an enhanced injury case is to prove the fact of enhanced injury by offering evidence that the design defect was a substantial cause of injury above and beyond what would have occurred without the defect. The plaintiff need not prove exact apportionment or that the defect was the sole cause of the injuries. The manufacturer is not liable for causing the initial collision, but may be liable for the increased harm. (Derived from Jahn v. Hyundai Motor Co. (n.d.).)