Casey v. Toyota Motor Engineering Manufacturing North America, Inc.
2014 U.S. App. LEXIS 20088
5th Cir.2014Background
- Diversity products-liability suit where Casey and Gillis sue Toyota entities over Dawna Casey’s fatal Highlander rollover.
- Casey asserted manufacturing and design defects in the side curtain airbag; other claims were dismissed or settled before trial.
- District court granted judgment as a matter of law for Toyota on airbag manufacturing and design-defect claims.
- Trial evidence showed the airbag remained inflated for about two seconds, not six, but no direct proof of a manufacturing defect or its cause.
- Court instructed de novo review of the Rule 50 motion; appellate review centers on whether the airbag’s performance proves a manufacturing defect or a safer alternative design.
- Court affirmed district court’s judgment for Toyota, finding no sufficient evidence of manufacturing defect or feasible safer alternative design.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Manufacturing defect requires deviation from specifications | Casey argues the airbag failed its specifications | Toyota contends deviation from specifications shown by performance failure is insufficient | Casey fails to prove deviation from specifications; no manufacturing defect |
| Safer alternative design existed | Casey asserts patent-based alternative is feasible | Toyota argues no evidence of feasibility or testing | No evidence of practical, tested, and economically feasible safer alternative design |
| Risk/utility and feasibility elements in design defect | Casey relies on patent to show alternative design would reduce risk | Defendant argues no risk-utility or feasibility demonstrated | Design defect claim rejected for lack of tested, feasible safer alternative and risk-utility analysis |
| Legal standard and evidence requirements for manufacturing defect under Texas law | Casey claims deviation from specifications shown by airbag performance | Toyota emphasizes need for specific defect evidence | Evidence insufficient to identify a manufacturing defect; manufacturing defect not proven |
| Scope of evidence for manufacturing vs design defect distinction | evidence of performance standards should fit manufacturing defect | standards about performance do not equal specifications | Evidence did not show manufacturing defect; remains a design-defect issue analysis |
Key Cases Cited
- Cooper Tire & Rubber Co. v. Mendez, 204 S.W.3d 797 (Tex. 2006) (defect must be identified; mere failure not enough)
- Ford Motor Co. v. Ridgway, 135 S.W.3d 598 (Tex. 2004) (circumstantial manufacturing defect evidence must be more than mere failure)
- Ledesma v. Ford Motor Co., 242 S.W.3d 38 (Tex. 2007) (specifications requirement; design vs. manufacturing distinction)
- Hodges v. Mack Trucks, Inc., 474 F.3d 188 (5th Cir. 2006) (risk-utility analysis required for safer alternative design)
- Harper v. Gen. Motors Corp., 61 S.W.3d 118 (Tex. Ct. App. 2001) (patents alone insufficient for safer alternative without testing)
- Gen. Motors Corp. v. Harper, 61 S.W.3d 118 (Tex. Ct. App. 2001) (evidence of economic feasibility required; testing needed)
- iLight Technologies, Inc. v. Clutch City Sports & Entertainment, L.P., 414 S.W.3d 842 (Tex. Ct. App. 2013) (deviation from performance standards not automatically manufacturing defect)
- Leverette v. Louisville Ladder Co., 183 F.3d 339 (5th Cir. 1999) (Mississippi law; extrapolated limitations on performance-standard proof)
- BIC Pen Corp. v. Carter, 346 S.W.3d 569 (Tex. Ct. App. 2008) (distinguishes manufacturing specifications from performance standards)
- Restatement (Third) of Torts: Products Liability § 2(a) (1998), — (—) (Restatement guidance on manufacturing defect standard)