Rooker v. Ford Motor Co.
100 So. 3d 1229
| Fla. Dist. Ct. App. | 2012Background
- Rooker was injured in a 2001 single-car rollover in a 1999 Ford Explorer she was driving for her boyfriend.
- Rooker sued Ford for strict liability, negligence, and related claims based on alleged defects in the design of the suspension, roof/structure, and occupant restraints.
- Ford moved for summary judgment, arguing Rooker failed to show the defects caused her injuries and that she was intoxicated.
- The trial court granted summary judgment; on rehearing Rooker submitted an expert-affidavit, which the court denied.
- The court held that disputed material facts existed regarding the roof/compartment design and occupant restraints, and reversed for remand.
- Issues remain whether roof/compartment design and restraint defects proximately caused injuries, and whether seat belt evidence is disputed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether disputed design defects create genuine issues of material fact | Rooker argues defects in roof/compartment and restraints caused injuries regardless of accident cause | Ford argues accident cause negates defects and no expert proof supports defects | Genuine issues exist; summary judgment improper |
| Whether seat belt defect/design issue remains | Record shows evidence that Rooker wore a seat belt; defect liability remains | Record silent or disputed on seat belt status | Seat belt design/defect issue remains material fact |
| Whether summary judgment was proper given the movant burden | Rooker provided sufficient evidence at this stage; burden not met to show no fact questions | Ford met its initial burden; burden shifted to Rooker to negate | Summary judgment improper; remand warranted |
Key Cases Cited
- Landers v. Milton, 370 So.2d 368 (Fla.1979) (burden on movant for summary judgment; opposing party must show genuine issues)
- Coral v. Garrard Cram Serv., Inc., 62 So.3d 1270 (Fla. 2d DCA 2011) (purpose of summary judgment is to resolve genuine issues of material fact)
- Hervey v. Alfonso, 650 So.2d 644 (Fla. 2d DCA 1995) (moving party bears heavy burden before nonmovant must show issues)
- Ford Motor Co. v. Hill, 404 So.2d 1049 (Fla.1981) (doctrine extending strict liability for defects beyond collision cause)
- Huff v. White Motor Corp., 565 F.2d 104 (7th Cir.1977) (interpretation of liability for defective parts in collisions)