Pruitt v. General Motors Corporation

Court of Appeal, Second District, Division Six
86 Cal. Rptr. 2d 4 (1999)

ELI5:

Rule of Law:

The consumer expectations test for a product design defect is reserved for cases where the everyday experience of users allows a conclusion that the product violated minimum safety assumptions. For complex products, such as automobile air bags, whose performance is beyond the common knowledge of lay jurors, the risk-benefit test is the appropriate standard for evaluating the defect claim.

Facts:

Norma E. Pruitt drove a 1991 Chevrolet Beretta manufactured by General Motors Corporation (GMC).
On March 22, 1995, while wearing her seatbelt and shoulder harness, Pruitt was involved in a low-impact collision when she turned left at an intersection.
The driver's side air bag deployed instantly upon impact.
The deployment of the air bag caused Pruitt to suffer three fractures of her lower mandible.
Pruitt, who was 75 years old, had a pre-existing medical condition of extreme bone atrophy in her jaw due to prior tooth loss, which made it unusually fragile and susceptible to injury.

Procedural Posture:

Norma E. Pruitt filed a product liability lawsuit against General Motors Corporation in a state trial court.
During the jury trial, Pruitt requested a jury instruction on the consumer expectations test for product design defects.
The trial court refused to give the consumer expectations instruction but did instruct the jury on the risk-benefit test and a failure-to-warn theory.
The jury returned a special verdict finding no defect in the vehicle, and the court entered a judgment in favor of General Motors Corporation.
Pruitt, as appellant, appealed the judgment to the intermediate court of appeal.

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Issue:

Does a trial court err by refusing to instruct a jury on the consumer expectations test in a product liability case concerning the complex technical design and deployment of an automobile air bag?

Opinions:

Majority - Gilbert, Acting P. J.

No, a trial court does not err by refusing to instruct a jury on the consumer expectations test in a case involving a complex product like an air bag. The consumer expectations test is limited to cases where a product's failure is so straightforward that the everyday experience of consumers is sufficient to determine it was defective. The deployment of an air bag is not part of the 'everyday experience' of the public, and its design involves complex technical trade-offs that are beyond the common knowledge of lay jurors. Therefore, expert testimony is required for the jury to properly evaluate the design by weighing its risks and benefits, making the risk-benefit test the exclusive and appropriate standard in such cases.

Analysis:

This decision reinforces the bifurcation of design defect tests established in Soule v. General Motors Corp., solidifying the rule that the consumer expectations test is inappropriate for technologically complex products. By categorizing air bag deployment as beyond the 'everyday experience' of consumers, the court mandates the use of the more rigorous risk-benefit analysis, which relies on expert testimony. This precedent makes it more difficult for plaintiffs to bring design defect claims for sophisticated products, as they cannot rely on simple consumer intuition and must instead engage in a costly and technical battle of experts to prove a safer alternative design was feasible.

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