AUSTIN - The Texas Supreme Court overturned a woman’s $26 million judgment against Honda Motor Co., ruling state law protects manufacturers against liability over products that meet federal automotive safety standards.
The presumption of liability can only be rebutted if plaintiffs prove the regulation didn’t address the risks the plaintiffs faced, or failed to protect the public against unreasonable risks at all. In this case, the Texas high court ruled Honda proved its minivan seatbelt design was safe and federal regulations anticipated the possibility passengers wouldn’t use it properly.
Sarah Milburn sued Honda after she was left quadriplegic in an accident involving a 2011 Honda Odyssey minivan. Milburn was sitting in the middle seat of an Uber when it was struck by a pickup and rolled over. The seatbelt was designed to be detached from the ceiling so the rear seats could be folded down, and Milburn claimed that was a design defect since vehicle owners might leave the ceiling anchor unattached and passengers wouldn’t know they were effectively unbelted.
A jury awarded Milburn $37 million after a three-week trial, which was reduced to $26 million to reflect liability of Milburn, the Uber driver and others. An appeals court upheld the judgment but the Texas Supreme Court reversed in a June 28 opinion by Justice Debra Lehrman.
Milburn presented expert witness Joellen Gill to testify owners wouldn’t keep the ceiling anchor fastened and passengers wouldn’t recognize the weren’t belted correctly. Steven Meyer, a mechanical engineer, also testified the risk of injury outweighed the utility of the belt’s design. Honda presented expert Michael Klima who testified the design was safe and met industry and government standards.
The Texas Supreme Court reversed the judgment, citing Section 82.008 of the Civil Code, enacted in 2003. That statute exempts manufacturers from liability if their product design complies with federal regulations and those standards apply to the risk the plaintiff is suing over. The manufacturer must prove the presumption applies, and plaintiffs can rebut it only if they prove the regulation wasn’t relevant to their injuries.
Milburn argued the federal regulation didn’t apply to the risk a vehicle owner would leave the seatbelt unattached to the ceiling anchor. The Supreme Court disagreed, ruling “seat-belt regulations are not limited to how seat belts perform in a crash; they also contemplate equipment types, locations, and designs for various seating positions.”
Plaintiffs can also rebut the presumption of nonliability by proving the regulation didn’t protect the public from unreasonable risks. The trial jury found that to be the case, but the Supreme Court again disagreed. The presumption of nonliability would have no effect if plaintiffs could defeat it simply by convincing a jury a product was defective, the court said.
“Accordingly, a determination that an applicable federal safety standard is inadequate to protect the public from unreasonable risks of injury requires something other than proof of a product’s defective design — that is, something more than a conclusion that the risks outweighed the benefits with respect to the particular product design at issue,” the court ruled.
In this case, Honda showed regulators considered the possibility the seatbelts would be misused and balanced that against the benefits of other aspects of the design.