Legal Alert: Court Rules Seatbelt Maker Not Liable in Fatal Car Accident
A recent decision from the United States District Court for the Northern District of Georgia makes clear that a plaintiff who brings a design defect claim must prove the defendant “actively participated” in the design of the allegedly defective product to prevail in the product liability case. In other words, mere involvement by a product supplier or seller in the design or manufacturing process is insufficient to maintain a product liability action against it. Notably, this important case highlights an argument available to product suppliers or sellers (as opposed to automobile manufacturers) when defending against a product liability lawsuit.
In Andrews v. Autoliv Japan, LTD, 2017 WL 85520, (N.D. Ga. Jan. 10, 2017), a federal court granted summary judgment in favor of a seatbelt maker. In this design defect case, a driver died in a single-car accident when his vehicle veered off an interstate and collided with three trees. The driver sustained life-ending injuries when his head slammed into the steering wheel at the time of impact, even though he was wearing his seatbelt and traveling within the posted speed limit. The driver’s widow sued various entities, including Autoliv, which supplied the seatbelt assembly installed in the car. The widow argued the design was defective on the grounds that the seatbelt assembly should have incorporated one of two alternate designs. In response, Autoliv filed a summary judgment, arguing it cannot be held liable for any alleged defect because it was not actively involved in designing the seatbelt assembly.
Ultimately, this case turned on the distinction between a “manufacturer”, subject to strict liability under O.C.G.A. § 51-1-11, and a “product seller,” which is not.
The federal court agreed with Autoliv. In reaching this ruling, the judge relied on a Georgia Court of Appeals case that held a component part supplier could not be held strictly liable as a manufacturer where it did not actively participate in the conception, design or specification of the final product. That court characterized the extent of the supplier’s involvement as providing confirmation that the specific design would perform adequately.
Similarly, the Andrews Court concluded the plaintiff’s evidence did not show that Autoliv was actively engaged in determining the specifications of the seatbelt at issue in this case. In this case, Autoliv provided several samples of seatbelt components but the car manufacturer performed the testing and ultimately decided on the final design. Accordingly, the court stated that the evidence supported only that Autoliv’s role was limited to choosing the components appropriate for the car based on the manufacturer’s specifications. Thus, Autoliv was not liable as a manufacturer under Georgia’s product liability statute.
Plaintiffs must establish that the defendant product seller or producer did something more than simply comply with a manufacturer’s specifications: plaintiffs must demonstrate active participation. The Andrews decision could have wide-reaching implications in future product liability actions in Georgia.