Jablonski v. Ford Motor Co., 955 N.E.2d 1138

Plaintiffs sued Ford in Madison County, alleging negligent design of the 1993 Lincoln Town Car fuel system and willful/wanton conduct seeking punitive damages.
The crash occurred when trunk contents punctured the rear fuel tank located behind the axle, causing a post-crash fire and injuries.
Plaintiffs asserted four design theories: (i) tank location aft of the axle, (ii) failure to shield the tank, (iii) failure to warn about trunk contents puncturing the tank, and (iv) post-sale warning duties.
Ford argued the Town Car complied with safety standards and that the aft-of-axle design was appropriate for its vehicle design and use.
The circuit court denied Ford’s motions; appellate court affirmed; Illinois Supreme Court granted review and reversed.
The case centers on whether the duty to design safely is satisfied by compliance with industry standards and whether a feasible safer design or warning obligation existed at the time of manufacture.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether risk-utility balancing governs the negligent-design duty	Jablonskis argue risk outweighed utility	Ford contends conformity to standards suffices	No; risk-utility balancing governs the duty
Whether conformity with industry standards is dispositive	Standards show unreasonableness	Standards are only a factor	Not dispositive; it is a factor to consider
Whether a postsale duty to warn is cognizable in Illinois	There is a continuing duty to warn of post-sale risks	No cognizable postsale duty under Illinois law	Not cognizable under current Illinois law in this context
Whether a voluntary undertaking created a duty to civilian customers	Trunk Pack undertaking created broader duty	Undertaking limited to police applications	No duty to civilian customers from voluntary undertaking
Whether plaintiffs presented sufficient evidence of unreasonableness to submit to the jury	Alternative designs were feasible and safer	No feasible, safer alternative; design reasonable for vehicle	Insufficient evidence to justify submitting first three theories to the jury

Calles v. Scripto-Tokai Corp., 224 Ill.2d 247 (2007) (establishes duty and risk-utility framework in negligent design)
Mikolajczyk v. Ford Motor Co., 231 Ill.2d 516 (2008) (risk-utility balanced approach in design defect cases)
Ruffiner v. Material Service Corp., 116 Ill.2d 53 (1987) (industry standards as a factor, not dispositive)
Darling v. Charleston Community Memorial Hospital, 33? Ill.2d 326 (1965) (early framework for balancing and duty concepts)