Synopsis of Rule of Law. Compliance with a statute is not a complete defense to a products liability claim. Risk-utility balancing is the standard for whether a product is manufactured or designed reasonably. Under the risk-utility test, compliance with federal standards is a factor for the jury to consider in deciding the question of reasonableness, but it does not render the manufacturer’s choices immune from liability.
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Issue. Whether Georgia law precludes a personal injury product liability claim against an auto manufacturer when the car is in compliance with the National Automobile Safety Act.
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Held. No. The notion that compliance with statute is complete defense is inconsistent with risk-utility analysis. Under the risk-utility test, compliance with federal standards is a factor for the jury to consider in deciding the question of reasonableness, but it does not render the manufacturer’s choice of design immune from liability. Evidence of such compliance is a significant piece of the evidentiary puzzle, but it does not bar manufacturer liability for design defect as a matter of law.
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A manufacturer's proof of compliance with industry-wide practices, state of the art, or federal regulations does not eliminate conclusively its liability for its design of allegedly defective products.
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