328 A.3d 986
N.J. Super. Ct. App. Div.2025Background
- Fatal accident involved a 2016 Honda CR-V crossing the center line and colliding head-on with another vehicle, causing both drivers' deaths.
- Plaintiff, as administrator of Dr. Ramage's estate, sued Honda, alleging the CR-V was defectively designed due to the absence of Lane Departure Warning (LDW) and Lane Keeping Assist (LKA) systems.
- LDW and LKA technologies were available in high-end 2016 CR-V models and as options on others, but not federally or state-mandated safety features for all vehicles.
- Plaintiff presented expert reports claiming these systems were feasible and could have prevented the crash.
- Honda moved for summary judgment, arguing no design defect as a matter of law since the vehicle met all mandatory safety standards and was otherwise reasonably safe.
- The trial court granted summary judgment for Honda, holding the absence of LDW/LKA did not render the vehicle unreasonably unsafe.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is a vehicle defectively designed for lacking available, but not required, driver-assist tech (LDW/LKA)? | Omission of LDW/LKA = defective design making car unsafe. | Not required by law; car was otherwise safe and met safety standards. | Absence of LDW/LKA does not establish a design defect as a matter of law. |
| Does the Products Liability Act require all available technologies to avoid strict liability? | All feasible safety technologies should be included to ensure safety. | Law does not mandate every available technology be included. | Manufacturer not required to install all available tech if car is reasonably safe. |
| Should the design defect issue have been submitted to a jury? | Sufficient evidence of feasible alternative designs (LDW/LKA); fact issue for jury. | No genuine issue of material fact; risk-utility favored defendant as a matter of law. | Issue was for the court; no triable issue since vehicle was reasonably safe. |
| Did plaintiff present evidence that LDW/LKA would have prevented the accident (causation)? | Evidence from experts these systems would have prevented the crash. | No proof driver would have activated/used or responded to systems; causation not fully developed. | Record insufficient on causation, but not reached due to design defect holding. |
Key Cases Cited
- Sun Chem. Corp. v. Fike Corp., 243 N.J. 319 (NJ Supreme Court clarified that NJ Products Liability Act governs all design defect claims)
- Roberts v. Rich Foods, Inc., 139 N.J. 365 (NJ Supreme Court described scope and purpose of NJ Products Liability Act)
- Dewey v. R.J. Reynolds Tobacco Co., 121 N.J. 69 (Defined requirements for design defect claims in NJ)
- Lewis v. Am. Cyanamid Co., 155 N.J. 544 (NJ Supreme Court explains risk-utility and alternative design standards)
- Gen. Motors Corp., 310 N.J. Super. 507 (Appellate Division describes jury's role in design defect cases if factual issues exist)
- Michalko v. Cooke Color and Chem. Corp., 91 N.J. 386 (Manufacturers can have duties to install safety devices beyond industry custom)