Alami v. Volkswagen of America, Inc.

Brief Fact Summary.

Silhadi Alami’s wife sued Volkswagen of America for design defects after her husband crashed his Volkswagen Jetta while driving under the influence of alcohol.

Synopsis of Rule of Law.

A defendant cannot be held liable for a design defect claim when the plaintiff’s illegal act caused the injuries for which the plaintiff seeks recovery.

Facts.

Under the influence of alcohol, Silhadi Alami died when he crashed his Volkswagen Jetta. Alami’s wife brought a design defects claim against Volkswagen due to her husband’s death. The New York Supreme Court granted summary judgment in favor of Volkswagen, and the appellate division affirmed.

Issue.

Whether a defendant can be held liable for the consequences of an illegal act committed by the plaintiff?

Held.

No. The decision of the appellate court is reversed and the motion for summary judgment is denied.

Dissent.

(Rosenblatt, J). The majority opinion incorrectly interprets the Barker/Manning rule, and allows people who are injured as a result of their own unlawful acts to recover damages.

Discussion.

The precedent established in Barker v. Kallash, 468 N.E.2d 39 (1984) and Manning v. Brown, 689 N.E.2d 1382 (1987) presupposes that a plaintiff cannot place a duty on the defendant that arises out the plaintiff’s illegal acts. Alami’s wife is not seeking to benefit from her husband’s death, but is imposing a duty on Volkswagen to produce products that do not advance the driver’s injuries.