Supreme Court
Am. Honda Motor Co. v. Milburn
- Case number: 21-1097
- Legal category: Products Liability
- Subtype: Design Defects
- Set for oral argument: September 13, 2023
Case Summary
The main issues on appeal are whether Honda defectively designed the seatbelt that caused Sarah Milburn’s injuries and whether Texas Civil Practice and Remedies Code Section 82.008’s rebuttable presumption of nonliability shields Honda from liability.
Honda designed a new ceiling-mounted detachable anchor seat belt system for the third-row middle seat of the 2011 Honda Odyssey. In November 2015, an Uber driver picked up Milburn and her friends in a 2011 Honda Odyssey. Milburn sat in the third-row middle seat and used the ceiling-mounted seat belt to buckle herself in. An accident caused the van to overturn on its roof. Milburn hung upside down by the shoulder strap portion of her seat belt, causing quadriplegia paralysis.
Milburn sued and settled with all defendants but Honda. Milburn asserted claims against Honda for negligence in designing, manufacturing, and marketing the van’s third-row middle seat belt system. Milburn alleged that the seat belt system was defective and dangerous and its intended method of use was counterintuitive. The jury found that Honda negligently designed the defective seat belt system. The jury also found that Honda was entitled to the Section 82.008(a) presumption of nonliability, but that Milburn rebutted it under Section 82.008(b).
The court of appeals affirmed, holding that Honda was entitled to the presumption of nonliability but that Milburn rebutted it and that the record contained evidence that the detachable anchor seat belt system was defectively designed, and a safer alternative exists.
Honda petitioned the Supreme Court for review, arguing that Milburn was required, but failed, to present sufficient expert testimony to rebut Section 82.008’s presumption of nonliability on regulatory inadequacy grounds. Honda contends that a “regulatory expert” must explain why the federal standards are inadequate to protect the public from unreasonable risk.
The Court granted Honda’s petition for review.
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