Pruitt v. General Motors Corp.

California Court of Appeal · Torts

Tortsproducts liabilitydesign defectconsumer expectations testrisk-benefit testfailure to warnproducts liabilitydesign defect

Facts

Pruitt was driving her 1991 Chevrolet Beretta, wearing her seat belt and shoulder harness, when she turned left at an intersection and collided with an oncoming car; the driver's side air bag deployed immediately. She suffered three fractures of her lower mandible requiring surgery and incurred substantial medical expenses. In her products liability action, she alleged that the air bag deployed in a low-speed collision and caused her injuries. At trial, the jury was instructed on risk-benefit design defect and failure to warn, but not on the consumer expectations test, and it found no design defect or failure-to-warn defect.

Issue

Was Pruitt entitled to a jury instruction on the consumer expectations test for alleged design defect where her claim involved an air bag that deployed in a low-impact collision? More specifically, does air bag deployment present a product-safety issue within the common knowledge and everyday experience of lay jurors, or does it require expert evaluation under the risk-benefit framework?

Rule

The consumer expectations test applies only in cases where the everyday experience of the product's users permits a conclusion that the product's design violated minimum safety assumptions regardless of expert opinion about the design's merits. When the product's minimum safety is not within the common knowledge of lay jurors and evaluation requires expert testimony and balancing of technical tradeoffs, the proper design-defect theory is risk-benefit, not consumer expectations.

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

In Sacramento, Elena Morris was injured when the side-impact restraint system in her sedan activated during a moderate collision at an intersection. She sues Silver Peak Motors, alleging the restraint system's deployment geometry was defectively designed and offers engineers' testimony that the system reflects tradeoffs among sensor thresholds, occupant position, and injury prevention.

Which jury instruction on design defect is most appropriate?

Explanation. The governing rule limits the consumer expectations test to cases where ordinary users' everyday experience permits jurors to determine that the design violated minimum safety assumptions without expert balancing. A modern restraint system involving deployment thresholds and technical tradeoffs is a classic design case requiring risk-benefit analysis, not consumer expectations. (Derived from Pruitt v. General Motors Corp. (n.d.).)