Goodner v. Hyundai Motor Co., Ltd.
2011 U.S. App. LEXIS 17279
5th Cir.2011Background
- Plaintiffs sued Hyundai under Texas design-defect theory after a 2007 crash that killed Sarah Goodner; R.G. survived with minor injuries.
- The 2005 Hyundai Tucson seat could recline; plaintiffs alleged reclining >45 degrees allowed ejection despite seatbelts.
- Jury found design defect producing cause, allocating fault 45% to R.G., 10% to Sarah, 45% to Hyundai; judgment split between parents for loss of companionship and mental anguish.
- District court denied Hyundai's Rule 50 motions challenging sufficiency of evidence for unreasonableness and causation; Hyundai appealed.
- Appellate review is de novo for Rule 50(d) judgments; Texas design-defect elements require (1) defect rendering product unreasonably dangerous, (2) safer alternative design, (3) defect producing the injury.
- Court held there was legally sufficient evidence to support the jury’s finding of unreasonableness, feasible safer alternatives, and producing-cause causation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the seat design was unreasonably dangerous | Goodner: five-factor risk-utility supports unreasonableness | Hyundai: no factor supports unreasonableness as a matter of law | Not legally unreasonable; jury could find unreasonableness |
| Whether a safer alternative design existed and was feasible | All-belts-to-seat or 45-degree limit feasible; 45-degree limit supported | Feasibility not proven; trial focused on causation | A 45-degree recline limit shown feasible and sufficiently proven |
| Whether the design defect was the producing cause of Sarah's death | Seat recline caused ejection, increasing injury risk; causation supports | Need for more direct causal testimony; contested inference | Sufficient evidence for producing-cause causation; jury could infer |
| Whether Hyundai is entitled to de novo review on the feasibility issue | N/A | Feasibility challenge preserved; de novo review appropriate | Appellate review limited; no manifest miscarriage; no reversal |
Key Cases Cited
- Timpte Indus., Inc. v. Gish, 286 S.W.3d 306 (Tex. 2009) (design defect elements and risk-utility framework in Texas law)
- Hernandez v. Tokai Corp., 2 S.W.3d 251 (Tex. 1999) (unreasonableness factors and common-knowledge considerations)
- Caterpillar, Inc. v. Shears, 911 S.W.2d 379 (Tex. 1995) (court considers consumer expectations in risk-utility analysis)
- Am. Tobacco Co. v. Grinnell, 951 S.W.2d 420 (Tex. 1997) (risk-utility framework and factor-based analysis for design defect)
- Ford Motor Co. v. Ledesma, 242 S.W.3d 32 (Tex. 2007) (causation standards and appellate review in product-liability cases)
- Seagram & Sons, Inc. v. McGuire, 814 S.W.2d 385 (Tex. 1991) (limits on common-knowledge and warnings considerations)
- Mosley v. Excel Corp., 109 F.3d 1006 (5th Cir. 1997) (causation and circumstantial evidence standards in Fifth Circuit)