Dawson v. Chrysler Corp.
630 F.2d 950 (1980)
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Rule of Law:
Under New Jersey strict products liability law, an automobile manufacturer can be held liable for a design defect if a jury determines, through a risk/utility analysis, that the product was not 'reasonably fit, suitable and safe' because a feasible alternative design could have prevented or mitigated injuries in a foreseeable accident, even if the vehicle's original design complied with all federal safety standards.
Facts:
- On September 7, 1974, Richard F. Dawson, a Pennsauken police officer, was driving his patrol car, a 1974 Dodge Monaco manufactured by Chrysler Corporation, on a rain-soaked highway while responding to a burglar alarm.
- Dawson lost control of the vehicle, which slid off the highway and struck an unyielding fifteen-inch diameter steel pole.
- The car impacted the pole backwards at a forty-five-degree angle at the left rear wheel well.
- The 1974 Dodge Monaco was constructed with a non-continuous frame, meaning there was a gap in the side frame between the front and rear seats.
- The force of the collision caused the pole to rip through the car's body at the frame gap, crushing Dawson between his seat and the roof's header area.
- As a result of the collision, Dawson suffered ruptured cervical vertebrae and a dislocated hip, which rendered him a quadriplegic.
- At the time of the accident, Dawson was not wearing a seatbelt.
Procedural Posture:
- Richard Dawson, his wife, and son originally sued Chrysler Corporation in the Court of Common Pleas of Philadelphia.
- Chrysler removed the case to the U.S. District Court for the Eastern District of Pennsylvania on the basis of diversity jurisdiction and then had it transferred to the U.S. District Court for the District of New Jersey.
- At trial, after the close of evidence, Chrysler's motion for a directed verdict was denied by the district court.
- The jury returned a verdict in favor of the Dawsons, awarding them substantial damages based on special interrogatories finding the car's design was defective.
- After the entry of judgment, Chrysler filed a motion for judgment notwithstanding the verdict (JNOV) or, alternatively, for a new trial.
- The district court denied both of Chrysler's post-trial motions.
- The district court then granted the Dawsons' motion for prejudgment interest.
- Chrysler, the defendant-appellant, appealed the judgment and the denial of its motions to the United States Court of Appeals for the Third Circuit.
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Issue:
Under New Jersey strict liability law, does an automobile's design constitute a defect if a jury determines, through a risk/utility analysis, that a feasible alternative design would have made the vehicle safer in a foreseeable collision, even if the original design complied with all federal motor vehicle safety standards?
Opinions:
Majority - Adams, Circuit Judge
Yes, under New Jersey strict liability law, an automobile's design constitutes a defect if a jury determines that a feasible alternative design would have made the vehicle safer in a foreseeable collision. The court held that an automobile manufacturer has a legal duty to design and produce a reasonably crashworthy vehicle, as accidents are considered an 'intended' use of the product. The controlling legal standard in New Jersey is not the Restatement's 'unreasonably dangerous' requirement, but whether the product is 'reasonably fit, suitable and safe for its intended or reasonably foreseeable purposes.' This determination is made by a jury through a risk/utility analysis, balancing factors such as the product's utility, the likelihood and seriousness of injury, and the availability and feasibility of a safer alternative design. The Dawsons presented sufficient expert testimony for a jury to find that a continuous frame design was a known, feasible alternative that would have caused the car to deflect off the pole and resulted in only minor injuries. The fact that Chrysler's design complied with all federal motor vehicle safety standards is not a complete defense, as Congress expressly preserved common law liability.
Analysis:
This decision exemplifies the significant power of state tort law to regulate product safety, even in a field with comprehensive federal regulations. The court's affirmation of the jury verdict underscores that, in jurisdictions applying a risk/utility test, compliance with federal standards is not a shield from liability but merely one factor for a jury to consider. The opinion's concluding remarks highlight a major tension in American law: the creation of a patchwork of safety standards by individual juries, which can impose conflicting design requirements on national manufacturers and potentially undermine other federal policy goals like fuel efficiency. This case serves as a powerful illustration of how products liability litigation can function as a form of 'ad hoc' regulation.
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