Limiting the Duties of Car Manufacturers to Reasonable Use – Mazda v. Walters

gold convertibleWhen companies manufacture an item for public consumption, they generally owe a duty to consumers to ensure that the item is safe for the purposes for which the public intended to use it. However, this does not mean that the product must be safe for every possible use that can be conceived. For instance, if a person decides to use a bed sheet as a parachute while skydiving, and it does not live up to the task, the bed sheet manufacturer will not be responsible for any injuries that might have occurred, unless it was explicitly advertising its bed sheet as a backup parachute. It did not intend for the bed sheet to be used in that way and can’t be held responsible for an individual’s decision to do so.  A recent case out of Virginia looks at how this doctrine applies to car manufacturers and when they can be held liable for designing and manufacturing a car in a way that allegedly causes injuries to a driver.

In Mazda v. Walters, Ms. Walters was driving her Mazda convertible, a Miata, down the highway in Virginia when a large unknown object began barreling down the road in her direction. Trying to avoid the object, she swerved across the highway and into a ditch by the side of the road. In the process, her Miata flipped, landing on its top. Ms. Walters’ car was a soft-top convertible, and at the time of the accident she was driving with the top on. In the crash, the top completely folded and compressed into the car, forcing the car structure to collapse and leading to Ms. Walters’ severe cervical spine injury.  Ms. Walters sued for damages, alleging that the design of the soft top latching was defective because it was not designed to stay latched and in place in the event of a rollover crash. In response, Mazda argued that it was under no duty to supply a soft-top convertible that would provide complete protection during a rollover. At trial, the lower court disagreed and allowed Ms. Walters to proceed on her claims against Mazda. Mazda appealed.

On appeal, the appellate court noted that, in Virginia, there is no duty for a car manufacturer to supply a completely crashworthy vehicle.  Accordingly, Ms. Walters’ only possible claim of duty on the part of Mazda was that Mazda was required to exercise reasonable care in designing a car that was reasonably safe for the purpose for which it was intended. Accordingly, the question became whether it was intended that that passengers driving soft-top convertibles be protected in rollover accidents. First, the court looked at the obvious nature of soft tops, which clearly provide less structure and protection than a permanent roof structure would. It noted that individuals purchasing convertibles clearly could not expect the same level of protection that one would get with a normal car. Second, it looked at the existing National Highway Transportation Safety Administration standards and noted that at the time of the accident, there were no industry safety standards requiring that convertible soft tops provide protection during a rollover crash. Indeed, the safety standards specifically excluded convertibles from requirements related to the strength of vehicle roofs.

In total, the court determined that there was no evidence to support the conclusion that rollover crashes were a reasonable intended use for a convertible, nor that convertible roofs should reasonably be expected not to collapse during a rollover crash.  Accordingly, the court held that Ms. Walters had not established an actual duty for Mazda to manufacture such a car, and Mazda could not be held liable for her injuries.

Any plaintiff considering a negligence or product defect claim must first determine whether the defendant that they are seeking to sue owed an actual duty to protect the plaintiff from the harm that occurred. Without a duty, a claim cannot stand.  When dealing with products, it is particularly important to ensure that the claim arises out of the ordinary and intended use of the product, rather than an altogether different use that a manufacturer may not reasonably have been able to anticipate. Our West Virginia car accident lawyers have been helping clients evaluate their product defect and personal injury claims throughout the state for more than 25 years. Located in Elkins, West Virginia, the firm represents clients in a wide range of injury, criminal defense, and bankruptcy matters. Call us at 1-877-637-5756 or contact us online for a free consultation.

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