Court: Court of Appeals for the Seventh Circuit; April 17, 2002; Federal Appellate Court
Pamela Harris filed a lawsuit against General Motors Corporation, alleging that the driver’s side airbag in her 1996 Chevrolet Cavalier failed to deploy properly after a minor collision. Initially filed in state court, the case was removed to federal court under diversity jurisdiction. The district court dismissed her claim based on res ipsa loquitur and later granted summary judgment on her remaining claims of strict liability, negligence, and breach of warranty. Harris appealed, arguing there were genuine factual disputes warranting a trial. The accident occurred on May 20, 1997, when Harris, driving at approximately 20 mph with her seatbelt fastened, collided with a vehicle that had pulled in front of her. Following the impact, while annoyed by the damage to her new car, she noticed the passenger side airbag deployed, but the driver’s side did not. Approximately 20 seconds later, after leaning forward, the driver’s side airbag deployed suddenly, causing her to lose consciousness and suffer injuries, including displaced neck bones. An eyewitness, John Marshall, corroborated her account of the delayed airbag deployment. After the accident, Harris’s car was taken to a GM dealer, which replaced the entire airbag system and disposed of the original components. When she sought legal counsel a month later, the damaged parts were no longer available. Harris's lawsuit, filed on May 19, 1999, included the claims of strict liability, negligence, breach of warranty, and res ipsa loquitur. In her defense against GM's summary judgment motions, she presented her own testimony, Marshall's eyewitness account, and intended to call her neurologist, Dr. Edward Eyerman, to testify about the causation of her injuries. However, the district court allowed Dr. Eyerman to discuss the nature of her injuries but not the timing of the airbag's deployment. Ultimately, the appellate court affirmed the district court's decision, agreeing that Harris could not prevail.
Harris submitted extensive evidence from GM, consisting of a list of owner complaints and 1,241 reports of airbag deployment issues in models like the Cavalier, along with a Recall Campaign Bulletin regarding inadvertent airbag deployments. The district court excluded this evidence, determining that Harris failed to demonstrate that the incidents were substantially similar to her own case, which involved a significant collision prompting airbag deployment. The court noted that the Recall Campaign was not relevant to Harris’s situation.
Harris's evidence only indicated the airbag deployed 15-20 seconds post-collision and her injuries, leading the court to rule in favor of GM on its summary judgment motion. For strict liability, Harris needed to prove the airbag system was unreasonably dangerous and defective when it left GM's control, which she failed to do. Similarly, for her negligence claim, she needed to show GM had a duty that was breached, causing her injuries, which she also did not accomplish.
Harris attempted to use res ipsa loquitur to address causation and defect issues, but Illinois law does not support this theory in cases where the product has been out of the manufacturer's control for a significant time. Additionally, she could not show that her accident was one that typically occurs without negligence or that GM had exclusive control over the airbag.
Harris also claimed GM was liable for breach of express and implied warranties, asserting the Cavalier did not function properly during a collision. However, she failed to provide evidence of a defect in the airbag system or a connection between any alleged defect and her injuries. Consequently, the court affirmed GM's summary judgment on all theories presented.
