Soule v. General Motors Corp.

Supreme Court of California · 1994 · Torts

TortsProducts LiabilityDesign DefectCrashworthinessCausationJury Instructionsstrict products liabilitydesign defect

Facts

Plaintiff's 1982 Camaro was struck near the left front wheel by another car, after which the wheel collapsed rearward and inward and the floorboard deformed upward into the passenger compartment. Plaintiff claimed a weak weld and defective frame-and-bracket design allowed the wheel to break free and caused severe ankle fractures; GM argued there was no defect and that the collision force alone caused the injuries. Both sides presented extensive expert testimony on metallurgy, biomechanics, engineering, crash testing, and accident reconstruction. The trial court instructed the jury on both Barker design-defect theories, including ordinary consumer expectations, and refused GM's requested instruction that there was no causation if the same injuries would have occurred even with a proper design.

Issue

Whether the ordinary consumer expectations test may be used in a complex automobile crashworthiness design-defect case where ordinary users lack a basis in common experience for judging how safely the product should perform, and whether refusal of a defense causation instruction stating that no defect is a legal cause if the same injuries would have occurred anyway was error requiring reversal.

Rule

Under Barker, the consumer expectations test is reserved for cases in which the everyday experience of the product's ordinary users permits an inference that the product failed to meet legitimate, commonly accepted minimum safety assumptions; when the product's safe performance under the circumstances is outside common experience, the jury must use the risk-benefit test. Expert testimony may not be used to tell the jury what ordinary consumers would or should expect. A party is entitled to a correct, nonargumentative instruction on a supported theory of the case, but civil instructional error warrants reversal only upon a showing of actual prejudice after examination of the entire record.

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

In Portland, Maya Ortiz was injured when a ceramic coffee mug's handle detached as she lifted the mug by the handle during normal use, spilling hot tea on her hand. At trial, she offers the mug itself and testimony that she used it in the ordinary way; the manufacturer insists expert testimony about kiln temperatures and glaze chemistry is required before the jury may consider design defect.

Which instruction is most appropriate on the design-defect issue?

Explanation. The consumer expectations test is reserved for cases in which ordinary users' everyday experience permits an inference that the product failed to meet legitimate minimum safety assumptions. A mug handle detaching during ordinary lifting is the kind of failure lay jurors can evaluate without technical balancing. Under the majority opinion, when common experience supplies the safety baseline, the jury may use consumer expectations.