Justia Products Liability Opinion Summaries

Shawn and Tanya Maywald were injured in a collision when a northbound driver fell asleep and crossed into their lane, striking their vehicle. The vehicle that caused the crash was a 2019 Toyota 4Runner, which lacked a lane departure warning (LDW) system. The Maywalds alleged that the absence of LDW rendered the 4Runner defective and unreasonably dangerous, and they sued Toyota and others for strict product liability, negligent design, and loss of consortium.The Superior Court in Navajo County granted summary judgment for Toyota, finding that the 4Runner was not defective or unreasonably dangerous and that the absence of LDW did not cause the accident. The Arizona Court of Appeals vacated that decision, holding that the Maywalds had presented sufficient evidence for their strict product liability claim to proceed. The appellate court found that the risk/benefit analysis for strict liability could consider alternative designs and that there were factual disputes regarding negligence and causation; it reinstated all of the Maywalds’ claims.The Supreme Court of the State of Arizona reviewed the case to clarify the requirements for strict product liability. The court held that a plaintiff must independently prove both that a product was defective and that the defect rendered it unreasonably dangerous. The court further clarified that the risk/benefit analysis must focus on the risks and benefits of the product as actually designed, not as compared to an alternative design. Applying this framework, the court concluded that the absence of LDW did not make the 4Runner defective for its ordinary use, so the Maywalds’ strict liability, negligent design, and derivative loss of consortium claims could not proceed. The Supreme Court vacated the decision of the Court of Appeals and affirmed the trial court’s summary judgment for Toyota. View "MAYWALD v. TOYOTA" on Justia Law

The Supreme Court held that the National Highway Transportation Safety Administration (the Agency) has not established a clear policy objective concerning automatic emergency breaking (AEB) technology that preempts state tort law claims based on an auto manufacturer's alleged failure to install AEB.Plaintiff sued Chrysler alleging negligence, defective product design, defective product warning, and wrongful death. Chrysler moved to dismiss the lawsuit, asserting that it was preempted given the Agency's objectives regarding the development and deployment of AEB technology. The trial court granted Chrysler's motion. The court of appeals reversed, concluding that the Agency did not intend to preempt tort claims based on the absence of AEB. The Supreme Court reversed the trial court's order, holding (1) the Agency has neither conveyed an authoritative statement establishing manufacturer choice as a significant federal policy objective nor made explicit a view that AEB should not be regulated; and (2) therefore, the Agency has not established a policy objective that actually conflicts with the claims at issue. View "Varela v. FCA US LLC" on Justia Law

Plaintiff was diagnosed with drug-induced lupus, allegedly a side effect from using Solodyn, a treatment for acne. Plaintiff sued Medicis Pharmaceutical Corporation, which manufactures and distributes Solodyn, alleging that Medicis knowingly represented and omitted material facts in connection with the sale or advertisement of Solodyn in violation of the Consumer Fraud Act (CFA). Plaintiff also alleged that Medicis failed to adequately warn her of the consequences of the long-term use of Solodyn. The superior court granted Medicis’s motion to dismiss. At issue on appeal was the learned intermediary doctrine (LID), under which a manufacturer satisfies its duty to warn end users by giving appropriate warnings to the class of persons who may prescribe or administer the product. The Supreme Court reversed the superior court’s order dismissing Plaintiff’s complaint, holding (1) the LID does not prevent Plaintiff from suing Medicis; (2) Plaintiff alleged sufficient facts to survive Medicis’s motion to dismiss with regard to her products liability claim; and (3) the CFA applies to prescription pharmaceuticals, and therefore, Plaintiff alleged an actionable claim under the CFA. View "Watts v. Medicis Pharmaceutical Corp." on Justia Law