Lawson v. Honeywell International, Inc.

Citations: 75 So. 3d 1024; 2011 Miss. LEXIS 506; 2011 WL 5027139Docket: No. 2010-CA-01924-SCT

Court: Mississippi Supreme Court; October 20, 2011; Mississippi; State Supreme Court

SummaryOriginalCytator Case TreatmentBackward CitatorAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

Pamela Lynn Lawson appeals the trial court’s summary judgment in favor of Honeywell International, Inc. regarding her claims under the Mississippi Products Liability Act (MPLA) and negligence stemming from injuries sustained in a car accident. The court affirms the summary judgment on the MPLA claim, determining that Honeywell does not qualify as a 'manufacturer' under the MPLA, thus not liable. Conversely, the court reverses the summary judgment on the negligence claim, stating that MPLA does not preclude common-law negligence claims against a product designer who neither manufactures nor sells the product.

The incident occurred on July 8, 2005, when Lawson lost control of her Jeep Cherokee, resulting in her ejection due to an allegedly defective Gen-3 seatbelt buckle designed by Honeywell, which was sold to Chrysler in the mid-1990s. Honeywell disputes its involvement in the design and claims no liability under the MPLA, arguing that the Act does not allow for claims against non-manufacturers or non-sellers. The trial court concurred, considering the MPLA as the exclusive remedy for products liability in Mississippi.

After the trial court denied Lawson's Motion for Reconsideration, she filed an appeal. The appeal addresses two main issues: whether the trial court erred in determining Honeywell was not a 'manufacturer' under the MPLA and whether it wrongly concluded that the MPLA is the sole remedy for products liability, thus barring her common-law negligence claim. The appellate court will review the summary judgment de novo, ensuring all evidence is considered favorably for the nonmoving party.

Honeywell's classification as a 'manufacturer' under the Mississippi Product Liability Act (MPLA) is at issue. The court's role is to interpret the statute's language without expanding or limiting its provisions, aiming to fulfill the Legislature's intent, which is determined by the statute's clear wording. The MPLA serves as the exclusive remedy for strict-liability claims concerning products with design defects that are unreasonably dangerous. It specifies that a manufacturer or seller is not liable unless the claimant proves, by a preponderance of the evidence, certain conditions relating to the product's defectiveness and causation.

Lawson contends that the term 'manufacturer' should include product designers based on the definition of 'manufacture' encompassing design. However, a plain-meaning analysis indicates that the term 'manufacturer' does not include mere designers. Mississippi law dictates that words in statutes are to be interpreted according to their common meanings, especially when no specific definition is provided. Consequently, the common or popular meaning of 'manufacturer' must be applied, and the court often consults dictionaries to establish these meanings.

'Manufacturer' is defined as a person or entity that produces or assembles products, while 'designer' refers to someone who creates designs for art or machines. The term 'manufacturer' does not encompass mere designers, as clarified by the Court's ruling in Scordino v. Hopeman Bros. Inc., which established that a manufacturer is someone who regularly creates or prepares goods for sale to the public. The Court explicitly stated that a designer does not 'produce' goods ready for sale or resale, thus excluding them from the definition of a manufacturer under strict products liability.

The trial court's decision to grant summary judgment to Honeywell regarding Lawson's design defect claim was affirmed, as a non-manufacturing product designer does not fall under the definition of a manufacturer in the context of the Mississippi Products Liability Act (MPLA). Honeywell contended that the MPLA eliminated all common-law negligence claims against non-manufacturers based on its broad language; however, the court emphasized that legislative intent must be derived from the entire statute, not isolated segments. The court adheres to the principle that new statutes do not overturn established legal principles unless there is clear legislative intent to do so.

Claims against non-manufacturing and non-selling designers are outside the scope of the Mississippi Products Liability Act (MPLA), which specifically addresses liability for manufacturers and sellers. The statute does not provide guidance on proving negligence against product designers, as the definition of 'manufacturer' does not encompass designers. The court emphasizes it cannot expand the statute's plain meaning or assume the legislature intended to include designers, as they are explicitly excluded. Prior case law, including Jowers v. BOC Group, Inc., supports that common-law negligence claims against non-manufacturers are not precluded by the MPLA. Consequently, the court reverses the trial court’s summary judgment in favor of Honeywell concerning Lawson's common-law negligence claim while affirming the judgment regarding Lawson's statutory claim under the MPLA. Claims against defendants who are neither manufacturers nor sellers remain permissible, leading to a remand for further proceedings on the negligence claim.

The court affirmed in part, reversed in part, and remanded the case, with justices Carlson, Dickinson, Randolph, Lamar, Kitchens, Chandler, Pierce, and King concurring. Lawson included Key Safety Systems, Inc. and Chrysler, LLC as defendants; however, Chrysler was removed from the lawsuit due to bankruptcy, and Key Safety settled with Lawson. Honeywell claims its predecessor, AlliedSignal, Inc., manufactured the seat buckle for Chrysler before selling that division prior to its merger with Honeywell, Inc. The court emphasized the principle of statutory construction, particularly the "plain meaning rule," which states that if a statute's terms are unambiguous, they should be applied according to their plain meaning, as established in previous cases. The definition of "manufacture" is crucial, as it is defined broadly by Random House Webster's Unabridged Dictionary. While Black’s Law Dictionary does not provide a definition for "designer," the court noted that historically, the definition of "manufacturer" under common-law strict liability aligns with the Restatement (Second) of Torts and that there is no evidence suggesting the Legislature intended to change this definition in the context of the Mississippi Product Liability Act (MPLA). The court affirmed that terms with clear common law meanings should retain those meanings unless the statute indicates otherwise.