Benavides v. Tesla, Inc
1:21-cv-21940
S.D. Fla.Jul 20, 2025Background
- Plaintiffs represent the estate of Naibel Benavides Leon (deceased) and Dillon Angulo, both injured in a 2019 Tesla Model S Autopilot crash in Key Largo, FL.
- The lawsuit, consolidated from two separate actions, alleges product liability claims against Tesla: defective design, failure to warn, defective manufacture, and negligent misrepresentation.
- The court granted summary judgment to Tesla on defective manufacture and negligent misrepresentation; only defective design and failure to warn proceeded to trial.
- Central pretrial dispute concerns the admissibility of evidence of other Tesla Autopilot incidents and reports from the National Transportation Safety Board (NTSB) and National Highway Traffic Safety Administration (NHTSA).
- Plaintiffs sought reconsideration of prior rulings precluding Board reports and limiting the scope of other incidents that could be introduced at trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of NTSB Board Reports (accidents other than subject) | Statute only bars reports about the accident at issue, not reports of other accidents | Statute bars all NTSB board reports in all civil suits; no exceptions | Ruled for Tesla: federal law bars use of Board reports in any civil suit, including factual sections |
| Admissibility of factual findings within NTSB Board reports | Only conclusions/opinions inadmissible; factual portions should be admitted | Statutory bar is total, stripes even factual portions | Ruled for Tesla: no part of NTSB Board reports are admissible |
| Introduction of 18 other accidents referenced in Tesla’s admissions | These accidents are substantially similar and should be admitted | Lack of sufficient detail to show substantial similarity | Limited: Tesla’s response to requests for admission (naming the 18) admissible, but no further detail |
| Introduction of 211 NHTSA accident reports for notice | Reports show Tesla had notice of a dangerous defect, requiring a relaxed substantial similarity | Differences too great; do not show substantial similarity | Allowed for limited purpose of notice, using a relaxed substantial similarity standard |
Key Cases Cited
- Campbell v. Keystone Aerial Surveys, Inc., 138 F.3d 996 (5th Cir. 1998) (federal law “flatly prohibits” admission of NTSB accident reports in civil litigation)
- Jackson v. Firestone Tire & Rubber Co., 788 F.2d 1070 (5th Cir. 1986) (for proving notice from prior accidents, substantial similarity standard is relaxed)
- Hessen for Use and Benefit of Allstate Ins. Co. v. Jaguar Car, Inc., 915 F.2d 641 (11th Cir. 1990) (other complaints about similar defects admitted to show notice)
- Sorrels v NCL (Bahamas) Ltd., 796 F.3d 1275 (11th Cir. 2015) (relaxed substantial similarity standard applies to notice evidence)
- Nachtsheim v. Beech Aircraft Corp., 847 F.2d 1261 (7th Cir. 1988) (substantial similarity less strict when evidence is for notice rather than causation)