Lawson v. Honeywell International, Inc.
75 So. 3d 1024
| Miss. | 2011Background
- Lawson alleges a defective Gen-3 seat belt buckle design caused ejection and injuries in a 2005 Jeep Cherokee accident.
- Lawson sues Honeywell International, Inc., asserting MPLA strict-liability and common-law claims against a designer who allegedly designed the buckle for Chrysler in the mid-1990s.
- Honeywell denies designing the buckle and argues MPLA is the exclusive remedy, excluding design-defect claims against nonmanufacturers.
- The trial court granted summary judgment for Honeywell on Lawson’s MPLA claim and dismissed Honeywell with prejudice.
- Lawson pursued reconsideration; the trial court’s judgment was final and Honeywell was removed from the suit.
- This appeal centers on whether a designer is a 'manufacturer' under MPLA and whether MPLA precludes nonmanufacturing negligence claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Honeywell a 'manufacturer' under MPLA? | Lawson argues designer falls within manufacture under MPLA. | Honeywell maintains MPLA excludes designers not manufacturing or selling. | Honeywell not a manufacturer; MPLA does not apply to designer. |
| Does MPLA preclude common-law negligence against nonmanufacturing designers? | MPLA should be interpreted as not precluding negligence claims against designers. | MPLA precludes all common-law claims for product defects against designers. | MPLA does not preclude common-law negligence against nonmanufacturing designers; remand for negligence trial. |
Key Cases Cited
- Scordino v. Hopeman Bros., Inc., 662 So.2d 640 (Miss. 1995) (defines manufacturer as those who regularly create and sell goods)
- Olson v. Ulysses Irrigation Pipe Co., Inc., 649 F. Supp. 1511 (D. Kan. 1986) (Restatement-based manufacturer concept for sale of goods)
- Thorp Commercial Corp. v. Miss. Road Supply Co., 348 So.2d 1016 (Miss. 1977) (statutory-intent approach to reversing established law)
- Manufab, Inc. v. Miss. State Tax Comm’n, 808 So.2d 947 (Miss. 2002) (look to total language to determine legislative intent)
- Kerr-McGee Chem. Corp. v. Buelow, 670 So.2d 12 (Miss. 1995) (untangles plain meaning vs. statutory construction)