Stokes v. Montana Thirteenth Judicial District Court
259 P.3d 754
Mont.2011Background
- Wrongful death and survival action arising from a Ford Explorer rollover that killed Peter Carter; Stokes as Carter’s personal representative sues Ford, Overland, and Durham.
- Stokes alleges Ford’s seatbelt system design, development, and testing caused injuries; also asserts strict products liability for a defective design.
- Overland allegedly failed to maintain the vehicle in a safe condition and is strictly liable for placing a defective vehicle in commerce.
- District Court ruled under Chapman v. Mazda that § 61-13-106, MCA, bars seatbelt evidence in negligence claims but not in products liability claims; required election between theories.
- District Court informed Stokes he must elect between negligence or products liability if seatbelt evidence is introduced; Stokes sought supervisory control arguing error of law one case only.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 61-13-106, MCA, bars seatbelt evidence in this case. | Stokes: statute does not apply when seatbelt evidence concerns the defect/condition of the occupant restraint system. | Ford: statute bars all seatbelt-use evidence in civil actions. | Statute does not prohibit seatbelt-use evidence when the seatbelt system’s condition is at issue. |
| Propriety of granting supervisory control over the district court. | Stokes argues extraordinary legal question warrants immediate resolution. | Ford/Overland contend ordinary review on appeal suffices. | The Court grants supervisory control due to a pure legal question with statewide importance. |
| If seatbelt evidence is admissible, should a limiting instruction be used? | Evidence should be allowed to show crashworthiness/seatbelt condition. | Evidence should be excluded or limited to avoid prejudice. | A proper limiting instruction can be crafted to confine evidence to seatbelt-condition relevance. |
Key Cases Cited
- S.L.H. v. State Comp. Mut. Ins. Fund, 15 P.3d 948 (Mont. 2000) (statutory purpose and admissibility considerations for seatbelt evidence)
- DePaepe v. Gen. Motors Corp., 33 F.3d 737 (7th Cir. 1994) (seatbelt evidence admissibility in crashworthiness/defective design)
- Wolhar v. Gen. Motors Corp., 686 A.2d 170 (Del. 1996) (seatbelt evidence limited purpose in crashworthiness cases)
- Clark v. Mazda Motor Corp., 68 P.3d 207 (Okla. 2003) (admissibility of seatbelt evidence where design is at issue)
- Bridgestone/Firestone, Inc. v. Glyn-Jones, 878 S.W.2d 132 (Tex. 1994) (seatbelt evidence in product design/defect cases)
- Olson v. Ford Motor Co., 558 N.W.2d 491 (Minn. 1997) (seatbelt evidence and statutory interpretation in crashworthiness context)