E2023-00488-SC-R11-CV
Tenn.Jul 21, 2026Background
- A child was seriously injured in a three-vehicle crash while riding in a Dorel booster seat used with a Ford seatbelt extender. 1
- The booster seat manual told users to contact a vehicle dealer for a seat belt extender if the vehicle belt was too short, while the Nissan manual warned never to use seatbelt extenders to install child restraints. 2
- Plaintiff sued Ford and Dorel under the Tennessee Products Liability Act, alleging failure to warn about using a seatbelt extender with a booster seat. 3
- The parties generally agreed Dorel’s booster seat and Ford’s extender were each sound for their intended separate uses, and the warning dispute focused on their combined use. 4
- The trial court ultimately granted Dorel summary judgment, and the Court of Appeals affirmed based on Coffman. 5
- The Supreme Court granted review to decide whether Coffman required dismissal of Plaintiff’s failure-to-warn claim against Dorel as a matter of law. 6
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Coffman bar failure-to-warn claims involving two sound products used together? 7 | Coffman is limited; Dorel may owe a duty for foreseeable misuse of its booster seat with Ford's extender. | Coffman broadly bars warning claims about another manufacturer's product. | No; Coffman does not mandate dismissal here. 8 |
| Is Dorel liable for failing to warn about foreseeable misuse of its own booster seat? 9 | Dorel's manual encouraged extender use and failed to warn of the combined-use danger. | No duty exists because the danger came from Ford's extender, not Dorel's product. | Potentially yes; Coffman does not foreclose such a duty. 10 |
Key Cases Cited
- Rye v. Women's Care Ctr. of Memphis, MPLLC, 477 S.W.3d 235 (Tenn. 2015) (summary judgment is reviewed de novo 11)
- Coffman v. Armstrong International, Inc., 615 S.W.3d 888 (Tenn. 2021) (TPLA duty to warn is tied to the defendant's own product as it existed when control was transferred 12)
- Davis v. Komatsu America Industries Corp., 42 S.W.3d 34 (Tenn. 2001) (component-part liability can arise when an integrated final product is defective 13)
- O'Neil v. Crane Co., 266 P.3d 987 (Cal. 2012) (distinguishes asbestos post-sale integration claims from combined sound-product cases 14)
- Rastelli v. Goodyear Tire & Rubber Co., 591 N.E.2d 222 (N.Y. 1992) (no duty to warn where one sound product is combined with another sound product causing the danger 15)
- Macias v. Saberhagen Holdings, 282 P.3d 1069 (Wash. 2012) (recognizes an exception when two sound products combine to create an unreasonably unsafe condition 16)
- Braaten v. Saberhagen Holdings, 198 P.3d 493 (Wash. 2008) (notes cases where two sound products together create a dangerous condition and a duty to warn 17)
- Tellez-Cordova v. Campbell-Hausfeld/Scott Fetzger Co., 28 Cal. Rptr. 3d 744 (Cal. Ct. App. 2004) (combination of two sound products can create a dangerous condition 18)