Whitehead v. Toyota Motor Corp.
897 S.W.2d 684 (1995)
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Rule of Law:
Under Tennessee's system of modified comparative fault, a plaintiff's fault is compared with a defendant's fault in strict products liability actions. This principle applies even in enhanced injury cases where the product defect did not cause the underlying accident.
Facts:
- On January 22, 1992, Mark D. Whitehead was driving a 1988 Toyota pickup truck.
- Whitehead's truck crossed the center line of the road.
- The truck collided head-on with another vehicle traveling in the opposite direction.
- Whitehead was injured in the collision.
- Whitehead alleged his injuries were enhanced beyond those he would have otherwise received because the truck's seat-belt system was defective and not sufficiently crashworthy.
Procedural Posture:
- Mark Whitehead and his wife (plaintiffs) sued Toyota Motor Corporation and the seller (defendants) in the United States District Court for the Eastern District of Tennessee.
- The defendants asserted the affirmative defense of comparative fault.
- The plaintiffs filed a motion for partial summary judgment seeking to dismiss the defendants' comparative fault defense.
- The district court granted the plaintiffs' motion, ruling that the comparative fault defense was not applicable in a strict liability action.
- The defendants sought and were granted an interlocutory appeal on the issue.
- The U.S. District Court certified two questions of law regarding the application of comparative fault to the Supreme Court of Tennessee.
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Issue:
Under Tennessee law, does the affirmative defense of comparative fault apply in a strict products liability action, including in an 'enhanced injury' case where the product defect did not cause the initial accident?
Opinions:
Majority - Drowota, Justice
Yes. The affirmative defense of comparative fault applies to strict products liability actions, including those involving claims of enhanced injury. The core purpose of Tennessee's adoption of comparative fault in McIntyre v. Balentine was to link liability with fault. The court reasons that strict products liability, while not requiring proof of negligence, is nonetheless based on a concept of 'fault' — the fault of placing a defective and unreasonably dangerous product into the stream of commerce. Because both the plaintiff's conduct (e.g., negligence causing an accident) and the manufacturer's conduct (e.g., selling a defective product) constitute forms of 'fault,' they can be compared by a trier of fact. This approach aligns Tennessee with the overwhelming majority of jurisdictions and does not undermine the policies of strict liability, as manufacturers remain strictly liable for defects, with recovery merely being reduced, not barred, by the plaintiff's contributing fault. The court further holds it would be illogical to apply this rule to strict liability generally but not to enhanced injury cases, as an 'enhanced injury' claim is simply the products liability component of the plaintiff's total damages, and the plaintiff's fault is a proximate cause of all resulting harm.
Analysis:
This decision officially integrates the doctrine of strict products liability into Tennessee's new comparative fault framework, established just a few years prior in McIntyre. It clarifies that a plaintiff's own negligence is no longer irrelevant in a strict liability claim, significantly altering the landscape of products liability litigation in the state. By adopting the majority view, the court harmonizes its tort law, ensuring that the principle of apportioning liability based on fault is applied consistently across negligence and strict liability actions. The holding on 'enhanced injury' cases prevents plaintiffs from isolating the product's role in worsening injuries to avoid scrutiny of their own conduct in causing the initial accident, a crucial clarification for future cases involving vehicle crashworthiness and other similar claims.
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