Kia Motors Corp. v. Ruiz
432 S.W.3d 865
| Tex. | 2014Background
- Ruizes allege a 2002 Kia Spectra’s driver-side air bag failed to deploy in a head-on crash, causing Andrea Ruiz’s death; Suzanna Ruiz sustained minor injuries from deployment of the passenger air bag.
- Jury found Kia negligently designed the air-bag system and apportioned fault between Kia and the other driver; trial court reduced damages by Kia’s fault share and excluded certain findings.
- Kia invoked a statutory presumption under Tex. Civ. Prac. & Rem. Code § 82.008(a) but the court of appeals held FMVSS 208 does not govern the alleged risk; the court remanded on the evidentiary issue.
- The trial court admitted a spreadsheet of 432 warranty claims, including 67 code-56 claims, about open or short circuits in air bags; Kia objected as hearsay and irrelevant.
- The Texas Supreme Court agrees the presumption does not apply, holds the evidence supports negligence, but reverses admission of the spreadsheet as harmful error and remands for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 82.008 creates a nonliability presumption | Ruizes contend FMVSS 208 compliance triggers presumption | Kia asserts presumption applies when design complies with applicable federal safety standards | Presumption does not apply; standard not governing the risk in dispute |
| Whether FMVSS 208 governs the product risk | FMVSS 208 risk includes air-bag deployment failure | Regulation governs crashworthiness, not deployment risk | FMVSS 208 does not govern the deployment failure risk here |
| Whether the evidence legally supports negligent design | Evidence identifies specific connector deficiencies causing open circuit | Ruizes failed to isolate a definite defect and excluded other causes | Evidence supports defect finding; not reversed on sufficiency grounds |
| Whether the spreadsheet of warranty claims was admissible and harmful | Spreadsheet relevant to notice and defect discussion | Spreadsheet unreliable; irrelevant to core issues | Admissibility was error, not waived; error harmful; remand for new trial |
Key Cases Cited
- Armstrong v. Nissan North America, Inc., 145 S.W.3d 131 (Tex. App.—Texarkana 2004) (admissibility of other incidents; similarity required for notice/value)
- Wright v. Ford Motor Co., 508 F.3d 263 (5th Cir. 2007) (FMVSS 111 and safety regulations; risk governed by regulation)
- Trenado v. Cooper Tire & Rubber Co., 465 Fed.Appx. 375 (5th Cir. 2012) (FMVSS 109; tests aimed at preventing tire failure)
- Cooper Tire & Rubber Co. v. Mendez, 204 S.W.3d 797 (Tex. 2006) (designating admissibility standards for expert testimony on defect)
- Ridgway v. Ford Motor Co., 135 S.W.3d 598 (Tex. 2004) (sufficiency and reliability of expert testimony in defect cases)
- Ford Motor Co. v. Ledesma, 242 S.W.3d 32 (Tex. 2007) (standard for admissibility of expert testimony in design-defect cases)
- City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (standards for reviewing medical-evidence and sufficiency on appeal)