AUSTIN - Earlier this month, the Texas Supreme Court granted Honda’s petition to review a $26 million judgment levied against the car company over an alleged negligently designed third-row center seat belt in a minivan.
According to Honda’s petition for review, the design at issue complies with Federal Motor Vehicle Safety Standards.
Honda asserts the case arises from an intersection collision that occurred while Sarah Milburn was a third-row passenger in a 2011 Honda Odyssey minivan during a ride arranged through Uber. After settling with the Uber, the minivan’s owner, and the driver, Milburn proceeded to trial on a products-liability claim that Honda negligently designed the minivan’s third-row center seat belt.
The jury found Honda liable based on the negligent-design claim and that federal safety standards are inadequate, awarding $37,615,817.64 in past and future damages. A trial court signed a final judgment awarding Milburn $25,924,214.16, which was affirmed on appeal.
“Texas law mandates reversal,” Honda’s petition for review states. “Federal preemption law also establishes an independent reason to reverse the judgment. The Legislature has provided that a car manufacturer is presumptively ‘not liable’ under a products-liability theory if the product’s design complied with mandatory federal safety standards, which the design at issue here indisputably does. A plaintiff can rebut that presumption by proving that those federal standards are inadequate to protect the public from unreasonable risks.
“Because the plaintiff here offered no such evidence, the no-liability presumption controls and the judgment must be reversed.”
The plaintiff in the case argues that the evidence supports the jury’s finding that Honda was negligent in designing a defective seat belt system.
“Before passengers get into the seat, Honda expects the vehicle’s owner or driver to pull the belt down from the ceiling and latch the ‘detachable anchor’ into an ‘anchor buckle’ located in the seat,” the plaintiff’s brief states. “According to Honda, this detachable seat belt system facilitates the use of its ‘magic seat’ – a marketing name for the third-row seat that folds down into the Odyssey’s floor.
"Honda knew that a passenger using the seat belt with the detachable anchor unlatched could be seriously injured or killed in a crash. But Honda did no analysis or testing to determine whether and to what extent owners, drivers, and passengers would actually use the detachable seat belt system in the manner Honda intended. Had Honda done so, it would have learned what later became obvious—that owners and drivers do not reliably maintain the detachable seat belt in the anchored position, and passengers do not reliably fasten it in the correct manner.”
Court records show several groups have filed amicus briefs in the case, including the Texas Civil Justice League, which contends that the case “demonstrates the ease with which legislatively enacted policy decisions may be subverted by erroneous evidentiary rulings and lax appellate oversight.”
Supreme Court case No. 21-1097