Swajian v. General Motors Corp.
1989 WL 61770, 1989 R.I. LEXIS 110, 559 A.2d 1041 (1989)
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Rule of Law:
Under Rhode Island common law, an adult motor vehicle operator has no duty to wear a seatbelt, and therefore, evidence of a person's failure to use an available seatbelt is inadmissible in a civil action to show comparative negligence, assumption of risk, or failure to mitigate damages.
Facts:
- In June 1986, Maureen Swajian was driving a 1986 GMC Jimmy 4x4, which was manufactured by General Motors Corporation (GMC).
- She was traveling alone at a speed between fifty and sixty miles per hour on Route 95 North.
- The GMC Jimmy rolled over several times during the drive.
- Swajian, who was not wearing the available seatbelt, was ejected from the vehicle during the rollover.
- She died shortly thereafter from the injuries she sustained in the accident.
Procedural Posture:
- Maureen Swajian's husband filed a wrongful death lawsuit against General Motors Corporation (GMC) in the United States District Court for the District of Rhode Island, a federal trial court.
- The plaintiff asserted products liability claims, alleging a defect in the vehicle caused the fatal rollover.
- Prior to trial, the plaintiff filed a motion in limine seeking to exclude all evidence of Mrs. Swajian's use or non-use of her seatbelt.
- The U.S. District Court determined that the motion involved an unsettled question of Rhode Island law and certified the question to the Supreme Court of Rhode Island for resolution.
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Issue:
Does Rhode Island law permit a fact-finder in a civil action for damages to consider evidence of a person's use or non-use of an available seatbelt system for injuries sustained in a motor vehicle accident?
Opinions:
Majority - Murray, J.
No. Rhode Island law does not permit a fact-finder to consider the use or non-use of an available seatbelt in a civil action for damages. The court holds that no common law duty exists for an adult to wear a seatbelt in ordinary vehicular travel. Because comparative negligence is premised upon the breach of a legal duty, the absence of such a duty means there can be no finding of comparative fault for failing to buckle up. The court rejected the argument that non-use constitutes a failure to mitigate damages under the 'avoidable consequences' doctrine, stating that this doctrine applies only to post-injury conduct, not to pre-accident precautionary measures. Finally, the court found the assumption of risk defense inapplicable, as failing to buckle up does not constitute a knowing exposure to a specific, known risk, such as an undetectable vehicle defect. The court concluded that imposing such a duty is a public policy matter best left to the legislature, which has repeatedly declined to enact a mandatory seatbelt law for adults.
Analysis:
This decision establishes a clear, bright-line rule in Rhode Island rejecting the 'seat-belt defense,' aligning the state with the majority of jurisdictions at the time. By refusing to create a common-law duty to wear a seatbelt, the court emphasized judicial restraint and deference to the legislature on matters of public policy. The ruling prevents defendants in personal injury and product liability cases from reducing their liability by arguing the plaintiff's injuries were worsened by not wearing a seatbelt, thereby simplifying tort litigation on this point and placing greater responsibility for crash-related injuries on the tortfeasor.
