South-Western Legal Studies in Business

Jury Could Hold Producer Liable for Injuries Despite Manufacturer Compliance with Federal Safety Standards
Description Appeals court upheld a jury verdict against a vehicle manufacturer based on a finding that a door latch on a pickup was defective and a substantial factor in the death of the driver. Compliance with federal standards for door latches does not create a presumption that the vehicle was not defective.
Topic Torts
Key Words Product Liability; Defect; Substantial Factor; Reckless Disregard; Federal Standards
C A S E   S U M M A R Y
Facts Clark was killed when he pulled out in front of another car and his Dodge pickup was struck on the side. Clark, not wearing a seatbelt, was ejected from the truck through a door that came open. His heirs sued, contending that the truck was defective because the door latch failed and was a substantial factor in his death. The jury, finding Clark and Chrysler equally liable, awarded Clark's heirs $3.2 million in compensatory and punitive damages. Chrysler appealed.

Affirmed. The fact that the door latch conformed with federal standards did not create a presumption that the product was not defective. It was for the jury to review the evidence. Given the evidence, it could find that Chrysler knew the latch would not hold under certain circumstances and that its failure was a substantial factor in the fatal injuries Clark suffered. There was reliable expert testimony about the problems with the latch that could lead the jury to its conclusion that Chrysler knew of the problem and had failed to remedy it.

Citation Clark v. Chrysler Corp., --- F.3d --- (2002 WL 31386161, 6th Cir., 2002)

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