Atlanta Appeals Court Finds Automaker Not Responsible for Fatal Accident

On September 12, the U.S. Eleventh Circuit Court of Appeals in Atlanta declined to revive a personal injury lawsuit brought by a woman whose daughter died in an automobile accident. The plaintiff was administrator of her daughter’s estate, and she brought a lawsuit against the manufacturer of her daughter’s car. Both a Georgia trial judge and the Court of Appeals said the plaintiff failed to present sufficient evidence to support her claims.

Hughes v. Kia Motors Corporation

Although this case was contested in Georgia courts, the actual accident occurred in Tennessee. In May 2005, the victim drove her Kia Optima automobile out of a restaurant parking lot in Chattanooga. While executing a turn, a Mack truck struck her car. The impact caused the Kia to collide with two parked cars, a tree, and several other objects, before coming to a stop near a private residence. Emergency personnel recovered the victim from the vehicle and transported her to a local hospital. She was initially breathing and responsive following the accident, but died of a traumatic brain injury the next day.

The victim’s mother (and executor) sued Kia in 2011, alleging the Optima suffered from design defects that contributed to her daughter’s death. The mother, a resident of Georgia, filed the lawsuit in Gwinett Count, but Kia had the case removed to federal court. In a situation like this, the federal court must follow the law of the state where the alleged tort occurred, which here is Tennessee.

Since this case was heard in federal court, federal law governed the admission of evidence. That proved critical here, as the plaintiff’s case against Kia relied on the proposed expert testimony of an engineer specializing in accident reconstruction. He argued there was evidence connecting the victim’s death to Kia’s failure to install a fuel shut-off switch in the car. The trial court excluded this testimony, however, finding it was based entirely on the expert’s own speculation. The court said the expert could not establish “actual causation,” as Tennessee law required.

The court said the expert could not overcome the presumption that the victim’s initial impact with the truck—rather than any design defect in the vehicle—caused her death. The expert conceded he could not eliminate the initial impact as the cause of death. According to the trial court, this rendered his subsequent testimony “unreliable.”

The plaintiff appealed, but the Eleventh Circuit found no fault with the trial court’s decision. The appeals court said the expert’s testimony was “vague,” and his ultimate “leap from data to opinion was too great” to be admitted as evidence. Without that evidence, the plaintiff could not sustain a claim under Tennessee law. The “actual causation” standard requires proof that, but-for Kia’s alleged negligence, the victim would still be alive. With the plaintiff failing to present any admissible evidence, the appeals court said the trial court properly granted summary judgment to Kia.

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