Lloyd v. General Motors Corp.

United States District Court for the District of Maryland · Torts

TortsProducts liabilityClass actionsEconomic loss doctrineclass certificationRule 23predominancesuperiority

Facts

Plaintiffs alleged that the seats in certain Ford Explorer and Mercury Mountaineer vehicles were defectively designed because they could collapse rearward in moderate-speed rear-impact collisions. They did not seek damages for personal injuries, but instead sought money damages in an amount necessary to strengthen or repair the seats. Compared with their earlier proposed class, Plaintiffs narrowed the class to one seating configuration and dropped claims requiring proof of reliance, leaving only negligence and strict products liability claims. They argued that these changes made class treatment manageable.

Issue

Whether the narrowed proposed class satisfied Rule 23(b)(3)'s predominance and superiority requirements for certification. The court also had to decide whether Maryland design-defect law in this case was governed by the consumer expectation test or the risk-utility test.

Rule

Under Rule 23(b)(3), a class may be certified only if common questions predominate over individual ones and a class action is superior to other available methods of adjudication; predominance requires issues that are readily susceptible to classwide proof and resolvable for each class member in a single hearing, and certification must be denied when complexity would degenerate into disorder. For the Maryland design-defect claims at issue here, the risk-utility test applies rather than the consumer expectation test, requiring assessment of the product's safety performance and whether a feasible, safer alternative design existed. In Maryland economic-loss cases proceeding under the exception to the economic loss doctrine, damages are measured by the reasonable cost to correct the defect.

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

A group of Maryland owners of 2014-2016 Raven Trail SUVs sues Northstar Mobility in federal court in Baltimore. They allege the front-seat frames are defectively designed because they may bend backward in rear-end crashes, and they seek only the money needed to reinforce the seats; no class member alleges any personal injury or identifies a specific crash involving the challenged seats.

Should the court certify the proposed Rule 23(b)(3) class if liability would require the jury to assess seat performance across many occupant sizes, crash types, and speeds, and also decide whether a safer feasible redesign and repair method existed?

Explanation. Under the majority opinion, certification fails where the jury would have to conduct an abstract, complex risk-utility analysis untethered to a specific accident and also determine feasible redesign and repair issues for the class as a whole. Predominance requires questions readily susceptible to classwide proof and resolvable for each class member in a single hearing, and certification should be denied when complexity would degenerate into disorder. (Derived from Lloyd v. General Motors Corp. (n.d.).)