D'AMARIO v. Ford Motor Co.
2001 WL 1472600, 806 So.2d 424 (2001)
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Rule of Law:
In a crashworthiness or enhanced injury case, the fault of a driver in causing the initial accident cannot be compared with or apportioned to the fault of a manufacturer whose defective product is alleged to have caused subsequent, enhanced injuries. A manufacturer's liability is limited to only those enhanced injuries proximately caused by its product's defect.
Facts:
- In one incident, Clifford Harris was a passenger in a Ford vehicle when the driver, who was allegedly intoxicated and speeding, crashed into a tree.
- Following the initial impact, a fire started in the engine, which spread and engulfed the car, causing severe burn injuries to Harris.
- Harris's mother, Karen D'Amario, alleged that a defective relay switch in the Ford caused the fire and resulting enhanced injuries, for which she sued Ford Motor Company.
- In a separate incident, Maria Nash was driving her General Motors vehicle when an intoxicated driver crossed the center line and collided with her car.
- During the collision, Nash's head struck an interior metal post, causing fatal injuries.
- Nash's estate alleged that a design defect in the vehicle's seatbelt failed to restrain her properly, leading to her death as an enhanced injury, and sued General Motors.
Procedural Posture:
- In the D'Amario case, plaintiffs sued Ford in a Florida trial court. The jury found for Ford after the trial court admitted evidence of the driver's intoxication and speed.
- The trial court then granted the plaintiffs' motion for a new trial, finding the evidence of intoxication was unduly prejudicial.
- Ford (appellant) appealed to the Florida Second District Court of Appeal, which reversed the order for a new trial.
- In the Nash case, the plaintiff sued General Motors in a Florida trial court. The jury found for GM after the trial court allowed apportionment of fault with the intoxicated non-party driver.
- The plaintiff (appellant) appealed to the Florida Third District Court of Appeal, which reversed and remanded for a new trial.
- The Supreme Court of Florida accepted jurisdiction over both cases due to the conflict between the district courts' decisions and consolidated them for review.
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Issue:
Does the principle of comparative fault permit a jury in a crashworthiness case to apportion fault between the driver who caused the initial accident and the manufacturer of a vehicle whose alleged defect caused only the enhanced injuries?
Opinions:
Majority - Per Curiam
No. The principle of comparative fault concerning the cause of the underlying crash does not ordinarily apply in crashworthiness cases. The court adopted the 'minority view,' holding that the initial collision in a crashworthiness case is presumed, and the manufacturer's duty is to design a vehicle that avoids unreasonable risk of injury in the foreseeable event of a collision. The initial accident is legally remote and merely furnishes the occasion for the manufacturer's alleged fault to cause a separate, enhanced injury. The court analogized this to medical malpractice, where a patient's conduct leading to an injury is not compared with a doctor's subsequent negligence that aggravates it. Allowing apportionment would confuse the jury by shifting focus from the product defect to the driver's conduct, especially with prejudicial evidence like intoxication. The 'enhanced injury' doctrine itself properly apportions damages by limiting the manufacturer's liability to only the additional harm caused by the defect.
Concurring in part and dissenting in part - Wells, C.J.
Yes. The majority's holding that comparative fault 'will not ordinarily apply' creates a vague rule that is difficult to administer, departing from established Florida precedent that applies comparative negligence in all products liability cases. The core issue is not whether to apportion fault, but how to handle prejudicial evidence like a driver's intoxication. Trial judges already have the discretion under existing evidentiary rules, such as section 90.403, to exclude evidence whose prejudicial effect outweighs its probative value. A new categorical rule is unnecessary, and the majority's analogy to medical malpractice cases involving indemnity and contribution is inapplicable to the comparative fault analysis required here. Juries are capable of apportioning fault among multiple proximate causes, and the existing legal framework is sufficient.
Analysis:
This decision establishes a significant exception to Florida's general comparative fault doctrine for crashworthiness cases, aligning the state with the minority of jurisdictions. By bifurcating the legal analysis of causation—separating the cause of the accident from the cause of the enhanced injury—the court makes it substantially more difficult for manufacturers to defend product liability claims by blaming the driver who initiated the accident. This ruling strengthens the position of plaintiffs in such cases by forcing the jury to focus solely on whether a product defect caused injuries beyond those expected from the initial impact, thereby reinforcing the policy goals of the crashworthiness doctrine.
