(CN) – Seats that recline by more than 45 degrees make Hyundai liable for the death of a 19-year-old Texas girl, the 5th Circuit ruled, affirming a jury’s verdict against the automaker for $810,000.
Sarah Goodner and her sister had gone to see their other sister play in a softball tournament five hours away from their home outside Dallas in July 2007. As 16-year-old R.G. began the long drive back, 19-year-old Sarah reclined the passenger seat of her family’s Hyundai Tucson SUV to nap.
R.G. fell asleep at the wheel with the vehicle’s cruise control set at 80 mph and began to drift off the road. Sarah woke her sister up, and R.G. overcorrected the SUV twice. The overcorrection caused the vehicle to leave the road, crash into a barbed wire fence and roll over three times before stopping.
Both girls were wearing their seatbelts, and R.G. suffered minor injuries. Sarah was ejected from the vehicle, however, and died while being airlifted to a local hospital.
The girls’ parents, Stuart and Lisa Goodner, sued Hyundai for product liability. The Goodners argued that the SUV’s front passenger seat and restraint system were defective because the seat could recline to an unsafe position, which their expert put at any recline more than 45 degrees.
After the Goodners rested their case, Hyundai said the Goodners failed to prove the seat’s design was unreasonably dangerous. The Northern District of Texas twice denied Hyundai’s bid for judgment as a matter of law.
Finding that the seat’s design defect caused Sarah’s death, the jury assigned 45 percent responsibility to R.G., 10 percent to Sarah and 45 percent to Hyundai. The jury awarded $900,000 each to Stuart and Lisa Goodner for mental anguish and loss of companionship. Based on the liability allocations, Hyundai owed each parent $405,000.
On appeal, Hyundai said the District Court should have granted its motion. The Korean automaker argued that the Goodners failed to prove each of three elements required to recover a products liability judgment under Texas law: (1) that the product was defectively designed so as to render it unreasonably dangerous, (2) that a safer alternative design existed, and (3) that the defect was a producing cause of the injury for which the plaintiff seeks recovery.
During the trial, the Goodners’ expert testified that seats reclined more than 45 degrees significantly increase risk of ejection, and that ejection increases the risk of injury by six to 13 times.
Thus the Goodners provided evidence that a safer alternative design, limiting the seat to recline to a 45 degree angle, would have prevented or reduced the risk of Sarah’s injuries, the New Orleans-based federal appeals court ruled.
To establish that this alternative design was feasible, the Goodners’ expert testified that other car manufacturers had limited their seats’ recline to 45 degrees, and a cross examination of Hyundai’s expert during trial found the vehicle in question limited its rear seats’ recline to 45 degrees.
“The feasibility of installing this design in the rear seats is some evidence that it would be possible to install this feature in the front seats,” Judge Patrick Higginbotham wrote for a three-judge panel.
Expert testimony and a comparison of Sarah’s injuries to those of her sister also gave the jury a basis to infer that the seat recline played a substantial factor in Sarah’s fatal injuries, the Aug. 19 decision states.
“Since causation is generally a question of fact for the jury, there are not enough inferences pointing against causation here to support overturning the jury verdict,” Higginbotham wrote.