Justia Products Liability Opinion Summaries

A fatal car accident involving an eighteen-year-old driving a 2013 Toyota Scion led to a lawsuit by the driver’s estate against Toyota and Subaru, who had jointly developed the vehicle. The plaintiff alleged negligence, product liability, and violations of North Carolina’s Unfair and Deceptive Trade Practices Act, claiming that design defects caused the occupant compartment to collapse and a fire to spread, ultimately resulting in the driver’s death. During discovery, the plaintiff requested extensive documents and depositions, including English translations of Japanese-language materials. Toyota and Subaru objected to several document requests and deposition topics, and disputes arose regarding the timing and sufficiency of their responses.The Superior Court of Robeson County granted the plaintiff’s motions to compel, ordered the production of additional documents (including English translations), and mandated that Toyota and Subaru’s corporate representatives testify to all noticed deposition topics without further objection. When the defendants failed to comply as ordered, the trial court imposed sanctions, deeming certain facts established against them—including elements of duty and breach in the plaintiff’s product liability claim—and struck their regulatory compliance defense. Toyota and Subaru appealed, challenging the discovery and sanctions orders.The North Carolina Court of Appeals vacated the sanctions order and reversed the requirement to translate documents but otherwise affirmed the discovery order, holding that most of the trial court’s actions were not an abuse of discretion. The Supreme Court of North Carolina reviewed only the remaining issues in the discovery order. It held that the trial court erred by enforcing a fourteen-day deadline for objections to document requests in deposition notices (rather than the seven days required by the rules), and by waiving defendants’ objections to deposition topics for not seeking a protective order. Accordingly, the Supreme Court reversed the relevant portions of the Court of Appeals’ decision, instructed it to vacate the discovery order, and remanded for further proceedings. View "Sessoms v. Toyota Motor Sales, U.S.A., Inc" on Justia Law