A ruling by the U.S. Court of Appeals for the 11th Circuit has cleared the way for a Mazda seat belt lawsuit to move forward. The suit is a product liability claim arising from a wrongful death in a single-car accident involving a 2005 Mazda 3. The vehicle went off Interstate 575 in Georgia, striking three trees. In the incident that occurred in April 2013, the driver of the vehicle was using a two-point seatbelt system as the accident occurred. The driver’s head, however, struck the steering column, resulting in injuries that led to his death.
The Original Mazda Seat Belt Lawsuit Claim
A civil action was brought by the driver’s wife against the seat belt manufacturer, Autoliv Japan, LTD. The initial claim, filed in September 2014, involved a product liability action brought in the State Court for Fulton County in Georgia. Issues in the case caused it to be removed to a higher court. The plaintiff alleged that the load-limiting mechanics in the seat belt was defective, leading to the driver’s death. An amended complaint was filed in March of 2015.
In separate actions, suits were also pursued against the manufacturer of the airbag system, Bosch LLC, and Mazda itself. Both those parties reached settlements with the driver’s widow and the administrator of his estate, leaving Autoliv as the sole ruminating defendant. Autoliv sought a summary judgment in March 2016, and the U.S. District Court for the Northern District of Georgia ruled in favor of the seat belt maker. The judge in the original case rules that Autoliv had assembled the seat belt system in accordance with specifications supplied by Mazda.
Appeals Ruling
A three-judge panel of the 11th Circuit ruled that Autoliv could be held liable under Georgia’s state product liability laws for a product that was defective or didn’t work as expected, even if that product was sold by the manufacturer. The core concern of the core was with whether the specific product, the seat belt, could be demonstrated to be the proximate cause of the injuries that occurred. On those grounds, the court reinstated claims in the Mazda seat belt lawsuit for negligence and punitive damages.
The 11th Circuit also found that while Mazda had worked with Autoliv in designing the seat belt, but it was not actively involved in its creation. Autoliv had presented several options to Mazda in the process, including ones with retractor settings that potentially might have limited fatal injuries the driver had sustained. The court also indicated that it believed the components were defective at the time they were delivered to Mazda for installation and that Autoliv should’ve addressed the problem at that time.
A third claim that a warning should’ve been included with the seat belt was not allowed to move forward. The court stated in its opinion that the claim had not been “plausibly pled” in the initial filing. The opinion was handed down on March 16, 2018.
Conclusion
In re-affirming previous rulings regarding defective products, the 11th Circuit made clear that claims of defective manufacture remain a viable basis for seeing damages in wrongful death cases. A manufacturer cannot hide behind distinctions between seller and supplier. Plaintiffs can and should pursue actions against all parties involved in the construction of a potentially defective product that injured a loved one.
Learn more about Defective Product Lawsuits.
