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Jackson v. General Motors Corp.

    Citation. 60 S.W.3d 800 (Tenn. 2001)

    Brief Fact Summary.

    Plaintiff lost control of his vehicle that was manufactured by Defendant, and sustained multiple fractures to his jaw. Although his seat was as far as possible from the steering wheel, Plaintiff contends that steering wheel was unreasonably dangerous, causing him to sustain the fractures. Plaintiff brought suit, and the district court granted Defendant’s motion for summary judgment. On appeal, the appellate court certified the question to the Tennessee Supreme Court of whether the plaintiff could rely upon the “consumer expectation test” to establish that the seatbelt was “unreasonably dangerous”?

    Synopsis of Rule of Law.

    Pursuant to Tennessee law, a plaintiff in a products liability action is entitled to demonstrate that a product was unreasonable dangerous under the consumer-expectation test, the prudent-manufacture test, or both.

    Facts.

    Mounce Jackson, Plaintiff, was driving a vehicle that was manufactured by General Motors Corp., Defendant. As Plaintiff was driving,Plaintiff lost control of the vehicle, due to slick road conditions, and crash into a tree. Plaintiff was traveling at approximately 19 to 23 miles per hour. Although Plaintiff was wearing his seat belt, he endured multiple fractures to his face because his jaw hit the steering wheel upon impact. Plaintiff contended that his driver seat was positioned as far from the steering wheel as possible. Plaintiff brought suit against Defendant in a products-liability action contending that the steering wheel was “unreasonably dangerous.” The district court granted Defendant’s motion for summary judgment. On appeal, the United States Court of Appeals for the Sixth Circuit certified the question to the Tennessee Supreme Court of whether the plaintiff could rely upon the “consumer expectation test” to establish that the seat belt was “unreasonably dangerous”?

    Issue.

    Whether, a products liability action is entitled to demonstrate that a product was unreasonable dangerous under the consumer-expectation test, the prudent-manufacture test, or both.

    Held.

    Yes, a products liability action is entitled to demonstrate that a product was unreasonable dangerous under the consumer-expectation test, the prudent-manufacture test, or both.

    Discussion.

    Pursuant to Tennessee law, a plaintiff in a products liability action is entitled to demonstrate that a product was unreasonable dangerous under the consumer-expectation test, the prudent-manufacture test, or both. Even though the consumer-expectation test may be difficult to apply in cases where the product, due to its complexities, prevents ordinary consumers from having a basis for reasonable expectations, this is not such a case here. In this case, ordinary consumers are familiar with seat belts. Further, even if seat belts have the ability to be technologically complex, it does not prevent seat belts from being well understood by the the public, as matter of their basic function. Thus, courts, in other states and in Tennessee, have specifically held that the consumer-expectation test is appropriate in products-liability actions regarding seat belts. Plaintiff has the burden to create a question of fact regarding whether his seat belt was more dangerous than would be contemplated by an ordinary consumer with ordinary, common knowledge. If Plaintiff properly establishes the question of fact, the jury must resolve the issue by applying their independent judgment. 


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