Long v. TRW VEHICLE SAFETY SYSTEMS, INC.
796 F. Supp. 2d 1005
D. Ariz.2011Background
- Rollover collision in La Paz County, AZ about June 19, 2005 involving a 2003 Ford Expedition; casualties included Cynthia Jo Johnson (deceased) and Sean McKnight with others as passengers.
- Plaintiffs allege strict product liability, negligence, and wrongful death against seatbelt designer/manufacturer TRW Vehicle Safety Systems, Inc. (VSSI).
- Earlier related case Long I involved AUS (alleged seatbelt manufacturer) and Ford/Continental; VSSI was later added as defendant; plaintiffs sought amendment to substitute VSSI but were denied.
- Plaintiffs settled with Ford and Continental; AUS claims were dismissed and the case was refiled as Long II against VSSI in state court, later removed to federal court.
- Defendant moved for summary judgment on claim preclusion/duplicative litigation, lack of admissible expert testimony, causation, and the component-supplier defense; court denied summary judgment in all respects.
- The court applied consumer expectation and risk/benefit tests to seatbelt design liability, concluding expert testimony is not categorically required and that triable issues remained on causation and the supplier defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claim preclusion/duplicative litigation bars the claims. | Long I did not final‑resolve the claims against VSSI. | Claims are barred by res judicata/duplicative litigation. | Not barred; claims survive. |
| Whether expert testimony is required to prove a design defect under Arizona law. | Experts are not necessary; defects can be shown through lay understanding of seatbelt safety. | Design defect requires expert proof under risk/benefit analysis. | No mandatory expert testimony; triable issues remain on defect under consumer expectation test. |
| Whether the design defect proximately caused the injuries. | Defect contributed to injuries despite rollover severity. | Rollover violence supersedes defect. | Triable issue; not as a matter of law superseding proximate cause. |
| Whether TRW is protected as a mere component supplier under the defense. | Defect in seatbelt itself; supplier cannot escape liability. | Component supplier defense relieves liability if part alone nondefective. | Defense not established as undisputed fact; denial of summary judgment on supplier defense. |
Key Cases Cited
- Golonka v. GM Corp., 204 Ariz. 575, 65 P.3d 956 (Ariz. Ct. App. 2003) (articulates strict liability and design‑defect standards in Arizona)
- Dart v. Wiebe Mfg., Inc., 147 Ariz. 242, 709 P.2d 876 (Ariz. 1985) (foundation for defective design and consumer expectations)
- Brethauer v. GM Corp., 211 P.3d 1176 (Ariz. Ct. App. 2010) (seatbelt consumer expectation exists; no expert needed under certain tests)
- Bell v. BMW, 181 Cal.App.4th 1108, 1129, 105 Cal.Rptr.3d 485 (Cal. App. 2010) (illustrates consumer expectation approach to design safety)
- Soule v. GM Corp., 8 Cal.4th 548, 34 Cal.Rptr.2d 607, 882 P.2d 298 (Cal. 1994) (design defect standards and consumer expectations)
- Petolicchio v. Santa Cruz County Fair & Rodeo Ass'n, Inc., 177 Ariz. 256, 866 P.2d 1342 (Ariz. 1994) (proximate cause generally a jury question)
- Robertson v. Sixpence Inns of Am., 163 Ariz. 539, 789 P.2d 1040 (Ariz. 1990) (intervening superseding causes and proximate causation)
- Woodward v. Chirco Construction Co., 141 Ariz. 520, 687 P.2d 1275 (Ariz. Ct. App. 1984) (expert testimony required for professional/lacunae in common knowledge)
- Gray v. GM Corp., 312 F.3d 240 (6th Cir. 2002) (discusses design defect claims in seatbelts (federal context))