772 F.Supp.3d 1111
N.D. Cal.2025Background
- Plaintiff Sylvia Jackson was severely injured (double leg amputation) when a Tesla Model 3 accelerated and pinned her between two cars in a Maryland parking lot; the Model 3's safety systems allegedly failed to engage.
- Jackson, a Maryland resident, sued Tesla in California state court, asserting strict products liability and negligence, among other claims; Tesla removed to federal court based on diversity jurisdiction.
- The Model 3 was designed and manufactured in California; Tesla continues to update its software from California; the car was purchased online in California and picked up in Maryland.
- Tesla moved to (1) disqualify the presiding judge for prior law firm connections, (2) transfer the case to the Southern District of Maryland, and (3) have Maryland law apply to the products liability claims.
- The case had been pending for over two years before Tesla filed these motions, with discovery complete and trial scheduled in four months.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judge Recusal | No basis for recusal: judge had no involvement with relevant cases at prior firm. | Prior employment at firm that litigated against Tesla warrants recusal. | Motion untimely and no reasonable basis for recusal; denied. |
| Transfer to Maryland | Strong California contacts, Tesla's design/manufacture in CA is central, and late motion prejudices her. | Forum and many witnesses are in Maryland; more convenient for trial. | Motion untimely and Jones factors favor keeping case in CA; denied. |
| Choice of Law (CA v. MD) | California law applies: Tesla's activities and updates are based in CA; CA has strong regulatory interest. | Maryland law: Incident occurred in MD; plaintiffs and driver are MD residents; MD has strong interest. | California law applies: greater impairment to CA’s interests if MD law were applied; regulatory focus prevails. |
| Application of Maryland Cap on Damages | California's open damages standard is relevant to deterrence and regulating Tesla. | Maryland’s statutory cap on noneconomic damages should apply. | California’s system of uncapped damages will apply. |
Key Cases Cited
- United States v. Hernandez, 109 F.3d 1450 (9th Cir. 1997) (standard for judicial recusal under § 455(a))
- United States v. Holland, 519 F.3d 909 (9th Cir. 2008) (reasonable observer standard for recusal)
- Jones v. GNC Franchising, Inc., 211 F.3d 495 (9th Cir. 2000) (factors for motions to transfer venue)
- Lou v. Belzberg, 834 F.2d 730 (9th Cir. 1987) (weight given to plaintiff’s choice of forum)
- Decker Coal Co. v. Commonwealth Edison Co., 805 F.2d 834 (9th Cir. 1986) (burden on party seeking transfer)
- Merrill v. Navegar, Inc., 26 Cal. 4th 465 (Cal. 2001) (strict liability and negligence as alternative claims)
- Chen v. L.A. Truck Ctrs., LLC, 7 Cal. 5th 862 (Cal. 2019) (governmental interest choice-of-law test in CA)
- Stangvik v. Shiley Inc., 54 Cal. 3d 744 (Cal. 1991) (California’s interest in regulating local manufacturers)
- Hurtado v. Sup. Ct. of Sacramento County, 11 Cal. 3d 574 (Cal. 1974) (choice-of-law government interest balancing)