Dawson v. Chrysler Corp

Brief Fact Summary.

Plaintiff’s car skid on a wet road and crashed into a pole. The pole penetrated the car’s frame upon impact and completely paralyzed Plaintiff. Plaintiff brought suit against Defendant for his injuries. The jury ruled in favor of Plaintiff and denied Defendant’s motion for judgment notwithstanding the verdict and a new trial. Defendant appealed.

Synopsis of Rule of Law.

A product is defective if a reasonable person would conclude that the magnitude of the scientifically perceivable danger as it is proved to be at the time of trial outweighed the benefits of the way the product was so designed and marketed.

Facts.

Richard Dawson (Plaintiff) became a quadriplegic after being involved in a car crash where his car skid on a wet road and hit a pole. The pole went through the car’s frame and cause Plaintiff’s injury. Plaintiff brought suit against Chrysler Corp. (Defendant) claiming that the frame was defective, thus causing his injuries. At trial, Plaintiff introduced evidence that a stronger frame would have decreased the risk of injury while still meeting federal safety standards. This improvement, however, would increase the cost of the cars.

Issue.

Whether a product is defective if a reasonable person would conclude that the magnitude of the scientifically perceivable danger, as it is proved to be at the time of trial, outweighed the benefits of the way the product was designed and marketed.

Held.

Yes. The court affirmed the district court’s ruling. A product is defective if a reasonable person would conclude that the magnitude of the scientifically perceivable danger, as it is proved to be at the time of trial, outweighed the benefits of the way the product was so designed and marketed.

Discussion.

The court determined that the jury did not commit an error in determining yhat Plaintiff’s car was defective. This determination utilizes seven factors to analyze the “risk/utility†balance of a product: 1) the usefulness and desirability of the product; 2) the safety aspects of the product; 3) the availability of a substitute for the product; 4) the ability of the manufacturer to cure the unsafe nature of the product without decreasing its usefulness or prohibitively increasing the cost; 5) the end user’s ability to avoid danger by using the product with care; 6) the end users awareness of the potential dangers of the product; and 7) the feasibility of the manufacturer spreading the loss by increasing the price of the product or buying insurance. The court calls on Congress to legislate a fix because it notes that this rule can lead to much uncertainty in automobile defect cases nationwide.