Capsule Summary: On June 21, 2013, a jury returned a defense verdict in a case involving a fatal rollover event in a 2009 Toyota Camry. The driver's personal representative for the estate brought a wrongful death suit against multiple defendants, alleging claims for strict products liability, breach of warranty, and negligence.
Case Information: Alacia C. Quinton as PR for the Estate of April Lynn Quinton, Plaintiff, v. Toyota Motor Corporation; Toyota Motor Sales U.S.A., Inc.; Toyota Motor Engineering and Manufacturing North America, Inc., Toyoda Gosei North America Corporation, Defendants, C/A No.: 1:10-cv-02187-JMC.
Date of Verdict: June 21, 2013
Venue: United States District Court, District of South Carolina, Aiken Division
Judge: The Honorable J. Michelle Childs
Factual Background: On October 14, 2009, April Lynn Quinton was driving a rented 2009 Toyota Camry in Aiken, South Carolina. She lost control of the vehicle while driving north into a left-hand curve. The car exited the road, struck an embankment, and rolled over several times before coming to rest on its wheels. Ms. Quinton was partially ejected and suffered severed head injuries from which she never recovered. She died on October 23, 2009.
Allegations and Procedure: Plaintiff filed a wrongful death and survival action against Defendants in the Aiken County Court of Common Pleas. In the Complaint, Plaintiff asserted claims for strict products liability, breach of warranty, and negligence. Plaintiff alleged the vehicle's roof structure and seat belt restraint system were defective generally. Plaintiff also alleged that the supplemental restraint system, which involved certain airbag technology, was defectively designed. More specifically, the 2009 Toyota Camry's supplemental restraint system included a curtain shield airbag ("CSA"). This system deploys above the vehicle's doors to protect a passenger's head from side impacts. Plaintiff alleged that the vehicle lacked a rollover-activated curtain shield airbag ("RCSA"). This system, which was not included in the 2009 vehicle, has a rollover sensor that deploys the curtain shield airbags when it senses the car is rolling over.
Defendants removed the case to the United States District Court of the District of South Carolina, Aiken Division. Defendants answered the Complaint and later filed a motion for summary judgment. The Court granted the motion with regard to Plaintiff's claims relating to a defective roof and defective seat belt restraint system. However, it denied summary judgment on Plaintiff's claim of a defectively designed supplemental restraint system.
At trial, the primary liability theory remaining and asserted by Plaintiff was the claim that the driver's side airbag failed to fully deploy. Plaintiff alleged this failure was the result of a hole in the airbag during manufacture (i.e., manufacturing defect). Defendants demonstrated that the hole found in the airbag post-accident was created during the severe four-roll rollover event as the bag was constrained and over-pressurized. In addition, the defendants presented evidence of the Quality Assurance/Quality Control procedures followed a the non-party manufacturers.
Experts: Plaintiff presented the following experts: Ron Kirk (accident reconstruction), Robert Bowser (airbag design), Richard Edwards (materials science), and Joe Burton (biomechanics). Defendants presented the following experts: Geoff Germane (accident reconstruction), Bob Gratzinger (roof structure), Mike Klima (airbag design), Karen Balavich (airbag/materials science) and Catherine Corrigan (biomechanics).
Alleged Damages: Plaintiff asked for $5 million.
Result: After four hours of deliberation, the jury returned their verdict in favor of the defendants.
Miscellaneous: This case also involved some pre-trial motions, one of which was a motion in limine by Plaintiff to exclude all evidence related to accident causation or fault. I will try to post the Court's Order on that motion later in the week, as it provides some interesting insight into our state's movement toward Restatement (Third) of Torts: Products Liability (1998) and crashworthiness. Also, special thanks to my friends and former colleagues, Dick Willis and Angela Strickland, for calling this case to my attention. Dick and Angela were on the defense trial team for this case. They were also kind enough to present the case at our products liability breakout session at the South Carolina Defense Trial Attorneys Association Summer Meeting a couple of weeks ago.
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