E2023-00889-SC-R11-CV
Tenn.Jul 21, 2026Background
- A rear-end and head-on three-vehicle collision killed Benjamin Woodruff and seriously injured Ethan Woodruff, who was using a Ford seatbelt extender with a Dorel booster seat in the back seat of the Nissan Juke. 1
- Ford’s extender was designed for large adults, sold through Ford’s distribution chain, and labeled to warn against incorrect use and use with child restraints. 2
- Plaintiff sued Ford and Dorel under the Tennessee Products Liability Act, alleging failure to warn that the extender should never be used with a booster seat. 3
- The trial court granted summary judgment to Dorel, denied Ford summary judgment, and later certified whether Coffman required dismissal of Ford’s failure-to-warn claim. 4
- The Court of Appeals held Coffman barred Ford’s claim, but the Tennessee Supreme Court granted interlocutory review after a mistrial in Ford’s case. 5
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Coffman bar Ford failure-to-warn claim? 6 | Woodruff said Coffman is limited and does not bar foreseeable-misuse claims involving two sound products. | Ford said Coffman means no duty to warn about risks from another manufacturer’s product. | No; Coffman does not mandate dismissal here. 7 |
| Does TPLA impose duty for combined use of sound products? 8 | Woodruff said Ford had to warn about foreseeable misuse of its own extender with a booster seat. | Ford said the extender was safe alone and Coffman foreclosed liability. | Possibly; the TPLA may allow a duty to warn of foreseeable misuse of Ford’s own product. 9 |
Key Cases Cited
- Coffman v. Armstrong Int’l, Inc., 615 S.W.3d 888 (Tenn. 2021) (TPLA duty to warn is limited to dangers existing when defendant’s product left its control; post-sale asbestos integration did not create liability 10)
- Metro. Gov’t of Nashville & Davidson Cnty. v. Tenn. Dep’t of Educ., 645 S.W.3d 141 (Tenn. 2022) (Rule 9 interlocutory review is limited to certified questions 11)
- Funk v. Scripps Media, Inc., 570 S.W.3d 205 (Tenn. 2019) (Rule 9 review limited to certified issues 12)
- Davis v. Komatsu Am. Indus. Corp., 42 S.W.3d 34 (Tenn. 2001) (TPLA may address liability involving component parts and defective final products 13)
- O’Neil v. Crane Co., 266 P.3d 987 (Cal. 2012) (no duty to warn about risks from post-sale integration of asbestos products 14)
- Rastelli v. Goodyear Tire & Rubber Co., 591 N.E.2d 222 (N.Y. 1992) (no duty to warn when one sound product is used with another manufacturer’s product 15)
- Macias v. Saberhagen Holdings, 282 P.3d 1069 (Wash. 2012) (recognizes cases where two sound products together create an unsafe condition 16)
- Braaten v. Saberhagen Holdings, 198 P.3d 493 (Wash. 2008) (notes some combinations of two sound products can create a duty to warn 17)