Mazda Motor Corp. v. Lindahl, 283

• Decision Date: 17 November 1997
• Docket Number: No. 283,1996,283
• Citation: 706 A.2d 526
• Parties: Prod.Liab.Rep. (CCH) P 15,222 MAZDA MOTOR CORPORATION, Defendant-Below Appellant, v. Jenna LINDAHL, Guardian For Megan Noel Lindahl and Jenna Lindahl, individually, Plaintiffs-Below Appellees. . Submitted:
• Court: Supreme Court of Delaware

Page 526

706 A.2d 526

Prod.Liab.Rep. (CCH) P 15,222

MAZDA MOTOR CORPORATION, Defendant-Below Appellant, v. Jenna LINDAHL, Guardian For Megan Noel Lindahl and Jenna Lindahl, individually, Plaintiffs-Below Appellees.

No. 283, 1996.

Supreme Court of Delaware.

Submitted: Nov. 17, 1997.

Decided: March 3, 1998.

Upon appeal from the Superior Court. REVERSED.

Court Below: Superior Court of the State of Delaware in and for Kent County, C.A. No. 92C-11-008.

Douglas B. Cats, and Noel E. Primos (argued), of Schmittinger & Rodriguez, P.A., Dover, for Appellees.

Somers S. Price, Jr. (argued), and Todd L. Goodman, of Potter Anderson & Corroon, Wilmington, for Appellant.

Before VEASEY, C.J., WALSH, HOLLAND, and BERGER, JJ., CHANDLER, Chancellor, ^* constituting the Court en Banc.

CHANDLER, Chancellor:

Plaintiff-appellee Jenna Lindahl ("Lindahl") filed suit against defendant-appellant Mazda Motor Corporation ("Mazda") alleging that a design defect in Mazda's seat restraint system caused her husband's death. At the close of Lindahl's case-in-chief, and again at the close of all evidence, Mazda moved for a directed verdict contending that Lindahl had failed to offer sufficient evidence that an alleged design defect was a proximate cause of any injuries to decedent. The Superior Court denied both motions. We conclude that Lindahl failed to provide sufficient evidence for the jury to find that the design defect was a proximate cause of any injury. Because Lindahl failed to establish a prima facie case, Mazda's motion for a directed verdict should have been granted. We reverse.

Facts

On March 17, 1992, a 1986 Mazda 626 driven by decedent Bradley R. Lindahl failed to negotiate a curve on County Route 18 in Little Heaven, Delaware. The vehicle plunged down an embankment, struck the side of a ditch, flipped end over end and tumbled through the air, striking the ground several times before it came to a stop 343 feet from the ditch. At trial, Trooper David Weaver testified that at the time of the accident, the asphalt road surface was smooth and dry, and there was no indication that decedent applied his brakes before the car left the road. The speed limit on County Route 18 is 50 miles per hour. According to Lindahl's accident reconstruction expert, decedent was traveling at a speed of at least 55.7 miles per hour. Decedent's blood alcohol content, measured shortly after the accident, was 0.17--well above the legal limit of 0.10. The only witness to the accident testified that he found decedent partially ejected through the driver's side window restrained only by the seat belt that remained buckled across his legs. The death certificate identifies the primary cause of death as exsanguination due to abdominal injuries. Massive head trauma is listed as an additional significant condition that contributed to the cause of death.

Decedent's car was equipped with "yielding" seats designed to cushion an occupant in an accident by collapsing in response to the force of a body thrust against the seat. According to Lindahl, ¹ decedent's yielding seats were negligently designed and, as a result, in a rear impact collision the seat back may bend backward, allowing an occupant to slide up the seat back unrestrained by the seat belt. Lindahl alleged that the yielding seat allowed her husband to be partially ejected from the vehicle, causing his death. For the purposes of this appeal, Mazda does not contest the jury's conclusion that the seat was negligently designed. Rather, Mazda appeals the Superior Court's denials of its motions for a directed verdict ² contending that Lindahl failed to offer sufficient evidence that the design defect was a proximate cause of any of decedent's injuries, let alone his death.

Lindahl offered the expert opinions of William Sherky, an accident reconstruction expert, and Louis D'Aulerio, a seat design expert, who testified that Mazda's seat design allowed decedent to slide up the seat back and be partially ejected from the vehicle. During Mazda's voir dire, D'Aulerio testified that he was neither a biomechanical expert nor an expert in medical treatment. ³ On that basis, Mazda moved to disqualify D'Aulerio from testifying as to the cause of decedent's injuries. The trial court granted the motion.

D'Aulerio later testified that decedent was "partially ejected, out of the vehicle where he then sustained the injury that killed him." ⁴ Mazda's counsel objected to this testimony as an opinion on the cause of injury, an issue on which D'Aulerio had been declared not competent to testify. The trial court sustained the objection and instructed the jury as follows:

[m]embers of the jury, the portion of the witness' last answer addressing the causation of any injury or death is stricken. You are to disregard it. ⁵

In response to Mazda's first motion for a directed verdict alleging that Lindahl failed to offer sufficient evidence of proximate cause and sufficient evidence of injury enhancement, Lindahl argued that there was a sufficient basis from which the jury could logically and reasonably conclude that the design defect was a proximate cause of decedent's death, even though the Court had disqualified D'Aulerio from testifying as to the timing or cause of decedent's injuries. The Superior Court agreed, stating that:

[c]ircumstantial evidence, expert testimony or common knowledge may provide a basis from which the causal sequence may be inferred in a particular case. Although expert testimony on biomechanics and greater detail on alternative design may have been helpful here, the Court is satisfied that from the totality of the evidence presented when it is viewed in the light most favorable to the plaintiff that a prima facie case has been established sufficient to allow the case to be presented to the jury. ⁶

Mazda then presented its case to the jury. Mazda's medical expert, Dr. Verne Roberts, testified that decedent's death was caused by exsanguination (internal bleeding), that the exsanguination was the result of damage to decedent's liver caused by compression of decedent's liver over the edge of his rib cage when the seat belt was forced against it, and that this compression could have occurred only when decedent was in the seat restrained by the seat belt--i.e., before the defective seat allowed decedent to ramp up the seat back and slip out of the belt. ⁷ He also testified that decedent's head injuries, eye injury and bruises were caused by contact with objects in the car before the seat defect allowed the seat to recline. ⁸

At the close of its case, Mazda renewed its motion for a directed verdict, reasserting its argument that Lindahl had failed to meet her prima facie burden on the issue of causation. Mazda further argued that the only evidence regarding causation was Roberts' opinion that none of decedent's injuries were attributable to the design defect. In response, plaintiff argued that the jury could draw inferences about injury and causation from D'Aulerio's testimony, as well as from common sense and experience. The trial court again denied the motion, ruling that injury causation could be shown through circumstantial evidence and common knowledge as well as through expert testimony.

The jury found that Mazda's and decedent's negligence ⁹ were proximate causes of decedent's death. Judgment on the jury verdict was entered against Mazda in the amount of $175,000.

Standard and Scope of Review

This Court's standard of review of a Superior Court ruling on a motion for judgment as a matter of law is "whether the evidence and all reasonable inferences that can be drawn therefrom, taken in a light most favorable to the non-moving party, raise an issue of material fact for consideration by the jury." ¹⁰ In other words, we will not disturb a Superior Court ruling denying a motion for judgment as a matter of law where "under any reasonable view of the evidence the jury could have justifiably found for [the non-moving party]." ¹¹

Crashworthiness Claims

Lindahl's defective design claim is based upon the "crashworthiness" doctrine, also known as the "second-collision" or "enhanced-injury" doctrine. ¹² As presented in the seminal case of Larsen v. General Motors, ¹³ the crashworthiness doctrine is an extension of the general principle that a manufacturer has a duty to design its products to be safe for normal use. ¹⁴ In Larsen, the Court found that an automobile manufacturer could reasonably expect its products to be involved in accidents and held that the duty to design products to be safe for normal use extended to the situation in which the product was involved in an accident. Thus, "[a]ny design defect not causing the accident would not subject the manufacturer to liability for the entire damage, but the manufacturer should be liable for that portion of the damage or injury caused by the defective design over and above the damage or injury that probably would have occurred as a result of the impact or collision absent the defective design." ¹⁵ As manufacturers are responsible for enhanced or additional injuries due only to the defective design (i.e., injuries "over and above" those that would be caused by a non-defective product in an accident), crashworthiness plaintiffs must show that the defective product was the proximate cause of the enhanced injuries--not the proximate cause of the accident itself.

The level of proof of enhanced injury varies by jurisdiction, but two general trends have emerged. The first, following Huddell v. Levin, requires a crashworthiness plaintiff to "offer proof of an alternative, safer design, practicable under the circumstances,.... offer proof of what injuries, if any, would have resulted had the alternative, safer design been used.... [and] offer some method of establishing the extent of enhanced injuries attributable to the defective design." ¹⁶ The second, following Fox v. Ford Motor Co. ¹⁷ and Mitchell v. Volkswagenwerk, A.G., ¹⁸ shifts to the defendant the...