Narrative Opinion Summary
The executor of an estate appealed a district court's summary judgment favoring General Motors Corporation (GM) in a strict liability tort case concerning an allegedly defective Buick LeSabre. The appellant claimed the vehicle's design inadequately protected passengers in side-impact crashes, resulting in a fatality. The district court granted GM's motion for summary judgment due to a lack of evidence from the plaintiff's primary witness, who failed to identify a specific design defect or feasible alternative design. Additionally, the plaintiff's reliance on a federal safety standard was deemed inapplicable, as it became effective after the vehicle's manufacturing date. The court upheld the summary judgment, noting that under Ohio law, a plaintiff must demonstrate a technically feasible alternative design that could have prevented the harm without impairing the product's usefulness. The appellant's argument of a common-law strict-liability claim, separate from statutory requirements, was also dismissed due to the lack of evidence of negligence. Ultimately, the judgment was affirmed, as the appellant did not meet the burden of proof required under Ohio law for a design defect claim.
Legal Issues Addressed
Common Law Strict Liability Preemptionsubscribe to see similar legal issues
Application: Claims based solely on strict liability without negligence do not survive under the Products Liability Act in Ohio.
Reasoning: His complaint, however, emphasizes strict liability without presenting evidence of negligence, contradicting his reliance on Carrel v. Allied Products Corp.
Consumer Expectation Standardsubscribe to see similar legal issues
Application: Plaintiff failed to demonstrate that an ordinary consumer in 1987 would expect to survive the crash, thus not meeting the consumer expectation standard under Ohio law.
Reasoning: The consumer expectation standard under Ohio law requires proof that an ordinary consumer in 1987 would expect to survive a crash at the speeds involved.
Feasible Alternative Design Requirementsubscribe to see similar legal issues
Application: The plaintiff must prove the existence of a feasible alternative design that could have prevented the harm without impairing the product's usefulness.
Reasoning: To establish a design defect under O.R.C. 2307.75, a plaintiff must demonstrate a technically feasible alternative design that would have prevented harm without significantly impairing the product's usefulness or purpose.
Relevance of Federal Safety Standardssubscribe to see similar legal issues
Application: The cited federal safety standard was not applicable as it was effective after the vehicle's manufacture.
Reasoning: McGrath cited Federal Motor Vehicle Safety Standard 214 to support his claims, but this standard was not effective until September 1993, rendering it irrelevant to the case.
Strict Liability in Tort Claimssubscribe to see similar legal issues
Application: The court reviewed the claim under Ohio law, requiring proof of a design defect and a feasible alternative design at the time of manufacture.
Reasoning: McGrath alleges the Buick LeSabre was defectively designed for side-impact crash protection, leading to Nicol McGrath's fatal injuries as a passenger.