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Atlanta Judge Says Seatbelt Producer Not Liable in Fatal Accident

Many Georgia car accidents are the result of a defect in the vehicle itself. Georgia product liability law recognizes three types of defects: manufacturing defects, design defects, and warning defects. The second group, design defects, includes any product that is not “reasonably suited to the use intended.” This means, for instance, that a product manufacturer may be held liable for damages if it selected an inappropriate or unsafe design.

Andrews v. Autoliv Japan, Ltd.

A design defect claim will only succeed if the plaintiff can prove the defendant actively participated in the design. Not every party who may have contributed some part of a vehicle is considered responsible for its design. A recent decision by a federal judge in Atlanta offers a helpful illustration.

In this case, a man died in a single-car accident when his vehicle “veered of Interstate 575 and collided with three trees,” according to court records. The widow of the deceased sued the company that manufactured the seatbelt system used in her husband’s car. The deceased was wearing his seatbelt at the time of the accident.

The widow argued the seatbelt system was defective and led to her husband’s fatal injuries. Specifically, she alleged a design defect based on the defendant’s failure to incorporate one of two alternate designed for the seatbelt assembly. In response, the defendant argued that the car manufacturer, not the seatbelt manufacturer, was responsible for the design of the seatbelt assembly.

The court agreed with the defendant. The trial judge granted summary judgment to the seatbelt manufacturer, holding the plaintiff failed to demonstrate the defendant was negligent under Georgia law.

The judge explained that the defendant supplied the “allegedly defective component,” i.e. the seatbelt assembly, to the car manufacturer. The car manufacturer provided “detailed specifications” for what it wanted. While the defendant provided “several samples of seatbelt components,” it was the car manufacturer tested these components and “ultimately decided” which specifications where appropriate for the vehicle.

The judge further pointed to previous decisions by the Georgia Court of Appeals in support of the rule that a manufacturer is only “strictly liable” for a defective design if it “actively” participates in the “conception, design, or specification” of the product. In one such case, the Court of Appeals noted a component supplier whose “only input into the design was limited to saying, in essence, that the particular [design] would perform adequately” was not liable for a defect. The judge in the present case said this same principle applied here.

The judge’s decision, it should be noted, does not absolve the auto manufacturer or any other party of possible liability. The only named defendant in this case was the company that produced the seatbelt system for the car manufacturer. It was not clear from the judge’s decision whether or not the widow has brought separate legal action against any other party arising from her husband’s death.

Source:

Opinion and Order, Andres v. Autoliv Japan, Ltd (N.D. Georgia, Jan. 10, 2017).