Sarah Elizabeth Woodruff ex rel. Ethan Woodruff et al. v. Ford Motor Company et al.Sarah Elizabeth Woodruff ex rel. Ethan Woodruff et al. v. Ford Motor Company et al.
HOLLY KIRBY, J., delivered the opinion of the court, in which JEFFREY S. BIVINS, C.J., SARAH K. CAMPBELL, and MARY L. WAGNER, JJ., joined. DWIGHT E. TARWATER, J., not participating.
Richard E. Collins and Dan Channing Stanley, Knoxville, Tennessee, for the appellant, Sarah Elizabeth Woodruff.
W. Bryan Smith, Memphis, Tennessee and Brian G. Brooks, Greenbrier, Arkansas, for the amici curiae, Tennessee Trial Lawyers Association.
OPINION
FACTUAL AND PROCEDURAL HISTORY
This case arises from a tragic three-vehicle accident in Knoxville, Tennessee. On August 23, 2013, Plaintiff/Appellant Sarah Woodruff’s husband, Benjamin Woodruff, was driving his 2012 Nissan Juke. Their two minor children were in the vehicle with him, both in the back seat. The Woodruffs’ younger child, four-year-old Kate, sat behind her father on the driver’s side in a forward-facing child seat with a five-point harness. Their older child, six-year-old Ethan, sat on the passenger side in a forward-facing high-backed booster seat.
Mr. Woodruff drove the Juke eastbound on John Sevier Highway and stopped in the center turn lane near the intersection with Austin Park Lane. At the same time, a Chevrolet Blazer driven by a drug-impaired driver was going westbound on the same highway. As Mr. Woodruff prepared to turn left, the driver of the Chevrolet Blazer negligently crossed the centerline and crashed head-on into Mr. Woodruff’s Juke. The collision caused the Juke to spin into the path of a 2001 Chrysler minivan, which hit the Juke on the driver’s side.
Mr. Woodruff died from injuries he sustained in the accident. Kate suffered some bruises and cuts but was otherwise physically unharmed.
Six-year-old Ethan sustained serious and disabling injuries in the crash, including head trauma and a broken femur. As a result, Ethan required surgery, hospitalization, and significant rehabilitation services.
At some point prior to the accident, Mr. Woodruff and Plaintiff Sarah Woodruff purchased Ethan’s booster seat, a Pronto model child restraint device manufactured by Defendant/Appellee Dorel Juvenile Group (“Dorel”).2 The booster seat came with an owner’s manual. The owner’s manual contained the following:
Check vehicle instructions for more information about air bag/child restraint use.
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If your seat belt is too short, contact your vehicle dealer for a seat belt extender. Do not route the seat belt any way except as shown in the instructions.
Mr. Woodruff purchased the 2012 Nissan Juke involved in the subject accident in February 2013. The owner’s manual for the Juke included the following:
Only NISSAN seatbelt extenders, made by the same company which made the original equipment seatbelts, should be used with NISSAN seatbelts.
Adults and children who can use the standard seatbelt should not use an extender. Such unnecessary use could result in serious personal injury in the event of an accident.
Never use seatbelt extenders to install child restraints. If the child restraint is not secured properly, the child could be seriously injured in a collision or sudden stop.
After he purchased the Juke, Mr. Woodruff experienced problems buckling Ethan’s booster seat into the seatbelt system in the Juke’s backseat. The receiving end of the seatbelt buckle was recessed in a way that made it difficult for Ethan to buckle himself into his booster seat without Mr. Woodruff’s assistance. To address the issues surrounding the recessed seatbelt buckle, on March 13, 2013, Mr. Woodruff purchased a seatbelt extender on eBay from a retailer called Seatbelt Extender Pros, LLC.3
The seatbelt extender Mr. Woodruff purchased was a product of Ford Motor Company (“Ford”). It was intended for use by large adults who do not physically fit in a standard-sized seatbelt restraint system.4 Ford commissioned the seatbelt extender to be used in the front seat of certain Ford Focus models.
Ford’s component manufacturer, Autoliv Safety Technologies, designed the extender to comply with federal safety standards applicable to seatbelt restraint systems. Ford reviewed and approved the design of the extenders and Autoliv manufactured them using Ford’s directions and specifications. Autoliv then sent the extenders to another Ford
The specific Ford seatbelt extender Mr. Woodruff bought was manufactured by Autoliv in 2010. It contained a label5 with the following:
Do not use seat belt extender –
Unless it is physically required to wear the vehicle’s safety belt.
If it causes the distance between the front edge of the extender buckle and the center of the occupant’s body to be less than 6 inches.
Incorrect use of extender may result in serious injury. Use extender only to the vehicle and seation [sic] position it was provided for.
Mr. Woodruff installed the seatbelt extender in the backseat of the Juke. When the August 13, 2013 accident occurred, Ethan was wearing the Ford seatbelt extender with the Dorel booster seat.
In July 2014, Plaintiff Sarah Woodruff filed a complaint in the Circuit Court for Knox County, on behalf of herself and her minor children. Among other claims, the original complaint brought personal injury claims under the Tennessee Products Liability Act (TPLA) against Ford and Seat Belt Extender Pros for the injuries Ethan sustained in the accident.6
Later, in January 2018, Ms. Woodruff amended her complaint to add other defendants, including Dorel. Eventually, the Plaintiff settled or non-suited all of her claims except for those against Ford and Dorel.
The Plaintiff’s product liability claims against both Ford and Dorel were based on alleged failure to warn. Specifically, the Plaintiff claimed that Ford and Dorel were required to warn or instruct consumers that a seatbelt extender should never be used in conjunction with a child’s booster seat, but they failed to do so. The Plaintiff alleged that their failure to warn of the risks associated with using a seatbelt extender with a booster seat caused Ethan’s injuries because the seatbelt extender failed to restrain the booster seat during the collision.
Similarly, in its product liability claim against Ford, the Plaintiff did not assert that the Ford seatbelt extender was defectively designed or manufactured for its intended purpose. It was generally undisputed that the seatbelt extender was fit for its intended purpose of restraining very large adults. The only defect identified by the Plaintiff’s expert witnesses was the lack of adequate warnings on the seatbelt extender label. The Plaintiff asserted that, for several years before the Woodruffs’ accident, Ford knew its seatbelt extenders were being misused with children’s booster seats but never updated or corrected the extender’s warning label.
In October 2018, Ford and Dorel both moved for summary judgment on the Plaintiff’s failure-to-warn claims. Both argued, among other things, that they had no duty to warn of risks associated with another manufacturer’s product. Dorel argued specifically that manufacturers have no duty to warn of the dangers of using their products with another manufacturer’s product. Ford argued it was neither a manufacturer nor a seller within the meaning of the TPLA, and it should not be held liable for injuries from a seatbelt extender manufactured by Autoliv and sold by a third-party vendor.
In response, the Plaintiff argued both Ford and Dorel failed to provide adequate warnings about a known misuse of their respective products. In a cross-motion for partial summary judgment, as well as her response to Ford’s summary judgment motion, the Plaintiff further argued that Ford was a manufacturer or seller under the TPLA because it controlled the design and distribution of the seatbelt extender.
In November 2019, the trial court granted Dorel’s motion for summary judgment. It found that the Plaintiff had submitted no proof that Dorel’s booster seat was defective, and it concluded that Ethan’s injuries were caused by the failure of the seatbelt extender. Because Dorel did not manufacture the seatbelt extender, the trial court concluded, Dorel had no duty to warn of the risks of using its booster seat with a seatbelt extender.
As to Ford, the trial court denied Ford’s motion for summary judgment and granted the Plaintiff’s cross-motion for partial summary judgment. The trial court acknowledged there was a factual dispute about Ford’s control over the design of the seatbelt extender, including its warning label. But it nevertheless concluded that Ford’s proprietary interest
Meanwhile, a separate case, Coffman v. Armstrong International, Inc., had been making its way through the appellate courts. The Court of Appeals issued its decision in Coffman in July 2019. See No. E2017-01985-COA-R3-CV, 2019 WL 3287067 (Tenn. Ct. App. July 22, 2019).
Later in November 2019, not long after the Court of Appeals’ decision in Coffman, the Plaintiff cited Coffman in a motion to reconsider the trial court’s prior order granting summary judgment in favor of Dorel. The Plaintiff argued in the motion that the earlier grant of summary judgment to Dorel should be reversed because the Court of Appeals in Coffman rejected the argument that, as a matter of law, manufacturers have no duty to warn about risks caused by another manufacturer’s product.
The trial court felt that the claims of the plaintiff in Coffman were distinguishable from the Plaintiff’s claims in this case. But it nonetheless believed that the Court of Appeals’ ruling in Coffman made it necessary to reconsider the earlier grant of summary judgment to Dorel.
In February 2020, the trial court vacated its previous grant of summary judgment in favor of Dorel. In response, in March 2020, Dorel filed a motion requesting the trial court’s permission for interlocutory appeal.
In March 2020, Ford filed another motion for summary judgment. Citing the trial court’s earlier ruling in favor of Dorel, Ford argued that it was entitled to dismissal as a matter of law. Ford contended it had no duty to warn consumers about risks associated with using the seatbelt extender with another manufacturer’s product. In response, the Plaintiff argued that Tennessee had never adopted a brightline rule that manufacturers have no duty to warn of risks associated with other manufacturers’ products.
In November 2020, the trial court denied Ford’s second motion for summary judgment. The trial court’s order did not directly address Ford’s argument that it had no duty under the TPLA to warn of another manufacturer’s product. Instead, the trial court reiterated its previous ruling that Ford was a “manufacturer” or “seller” of the seatbelt extender under the TPLA.
In January 2021, this Court issued its opinion in Coffman, reversing the Court of Appeals and holding that the defendants in that case could not be “held liable for injuries resulting from products they did not make, distribute, or sell.” 615 S.W.3d 888, 900 (Tenn.
In their trial court filings, Ford and Dorel argued that Coffman foreclosed the Plaintiff’s failure-to-warn claims by establishing that, as a matter of law, manufacturers have no duty to warn of risks associated with another manufacturer’s product. The Plaintiff argued that her claims were distinguishable from Coffman and that Coffman did not foreclose claims based on foreseeable misuse.
In March 2023, the trial court reinstated its previous grant of summary judgment to Dorel, concluding that Dorel “had no duty to warn with regard to the seatbelt extender that it did not manufacture or sell.” However, the trial court denied summary judgment to Ford. Because Ford distributed and sold the seatbelt extender, the trial court found, Coffman did not require it to grant summary judgment in favor of Ford.
The Plaintiff appealed the trial court’s reinstatement of summary judgment in favor of Dorel.7
In May 2024, the Court of Appeals issued an opinion affirming the trial court’s decision to grant summary judgment to Dorel. Woodruff ex rel. Woodruff et al. v. Ford Motor Co. et al., No. E2023-00488-COA-R3-CV, 2024 WL 2738197, at *9 (Tenn. Ct. App. May 28, 2024) (hereinafter Dorel). Based on this Court’s opinion in Coffman, the Court of Appeals held that Dorel was entitled to judgment as a matter of law.8 Id. at *8. The Court of Appeals determined that its holding pretermitted other issues raised by Dorel on appeal.9 Id. at *6, 9.
We granted the Plaintiff permission to appeal.10
This case is an appeal from a grant of summary judgment. “We review a trial court’s ruling on a motion for summary judgment de novo, without a presumption of correctness.” Rye v. Women’s Care Ctr. of Memphis, MPLLC, 477 S.W.3d 235, 250 (Tenn. 2015). Summary judgment is appropriate “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”
On appeal, the Plaintiff raises a single issue, as stated in the Plaintiff’s Rule 11 application:
Whether Coffman v. Armstrong International, Inc., 615 S.W.3d 888, 897 (Tenn. 2021), defeats Plaintiff’s claim against Dorel for failing to warn of the dangers associated with using a seatbelt extender to install the subject booster seat, when Dorel negligently and recklessly instructed consumers to “contact your dealer for a seat belt extender” if “your vehicle belt is too short.”
Thus, the Plaintiff asks us on appeal to address whether Coffman requires dismissal as a matter of law of the Plaintiff’s failure to warn claim against Dorel relating to its booster seat used in combination with a seatbelt extender manufactured and sold by another manufacturer.11
As background for our consideration of this issue, we briefly review pertinent statutory provisions. The Tennessee Products Liability Act (TPLA) governs actions for personal injury, death, or property damage caused by defective or dangerous products.
Under the TPLA, “[a] manufacturer or seller of a product shall not be liable for any injury to a person or property caused by the product unless the product is determined to be in a defective condition or unreasonably dangerous at the time it left the control of the manufacturer or seller.”
In this case, the Plaintiff claims that Dorel’s booster seat is unreasonably dangerous when used in combination with a seatbelt extender. She asserts that the owner’s manual endorsed this misuse of Dorel’s product, and that Dorel had a duty to warn consumers against the misuse by including adequate warnings and instructions in the owner’s manual.
Dorel argues that the Plaintiffs’ claims fail as a matter of law under this Court’s holding in Coffman. Dorel describes Coffman as holding that a manufacturer such as Dorel has no duty to warn of dangers associated with combining its product with another manufacturer’s product.
Thus, to resolve the issue in this appeal, we must examine Coffman.
Coffman
In Coffman, a retired equipment mechanic alleged that he developed mesothelioma from exposure to asbestos-containing materials in his workplace. 615 S.W.3d at 891. In his work, the plaintiff mechanic repaired and replaced equipment that included pumps, valves, steam traps, gaskets and piping. Id. He asserted that the materials needed and used to repair and maintain the equipment contained asbestos. Id. at 892. The asbestos-containing materials were neither manufactured nor sold by the equipment manufacturers; the materials were integrated into the equipment after it was sold by the equipment manufacturers. Id.
The plaintiff filed a product liability lawsuit against several defendants, including the manufacturers of equipment the plaintiff repaired and maintained in his work. Id. at 891–92. The lawsuit claimed the defendant equipment manufacturers were liable under the TPLA for failing to adequately warn users about the risks associated with integrating asbestos-containing materials into the equipment post-sale. Id. at 892. Though the asbestos-containing materials were manufactured and sold by other entities without the involvement of the defendant equipment manufacturers, the plaintiff alleged that the
The equipment manufacturers moved for summary judgment on the grounds that they had no duty to warn of the risks of asbestos exposure arising from products that they did not make, sell, or distribute. Id. The trial court granted summary judgment in favor of the defendants on the failure-to-warn claims, and the Court of Appeals reversed. Id. at 892–93. This Court granted permission to appeal on the question of whether the equipment manufacturers “had a duty to warn of the dangers associated with the post-sale integration of asbestos-containing materials manufactured and sold by others.” Id. at 894.
The Court in Coffman answered the question on appeal by interpreting the language of the TPLA. Id. at 895. It noted first that the TPLA specifically states that manufacturers and sellers are not liable for injury caused by a product unless it is “in a defective condition or unreasonably dangerous at the time it left the control of the manufacturer or seller.” Id. (quoting
Second, Coffman pointed out that the definitions of “unreasonably dangerous” and “defective condition” in the TPLA “link a defendant’s liability to the defendant’s own product.” Id. at 896–97 (citing
Under those circumstances, the Court held, the equipment manufacturers had no duty to warn of the dangers of asbestos. The Court rejected the plaintiff’s argument that the “TPLA anticipates that manufacturers are liable for the foreseeable alterations, changes, improper maintenance, or abnormal use of their products” and found it “dispositive that the end-products at issue on this appeal were neither made nor sold by the Equipment Defendants.” Id. at 897. Coffman emphasized that this holding was “based on the language of the TPLA.” Id. at 899. Coffman also cautioned that its holding was limited: “Again, this appeal deals strictly with the [equipment manufacturers] in situations where there was
Whether Coffman Mandates Dismissal
Here, the Court of Appeals found that the holding in Coffman mandated dismissal of the Plaintiff’s failure-to-warn claims against Dorel:
In this case, Plaintiff argues that Dorel’s booster seat was defective because its included instruction manual failed to adequately communicate the danger of using a seat belt extender with a booster seat. Throughout her pleadings about the danger that Dorel should have warned against, Plaintiff references other products, namely, seat belt extenders. However, as our Supreme Court recognized, the TPLA’s provisions “link a defendant’s liability to the defendant’s own product, not the product of another manufacturer.” Id. at 897. The Coffman majority was not persuaded that the Equipment Defendants’ products were defective because they later were integrated with unsafe asbestos-containing replacement parts.
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Here, what made the booster seat unsafe and what created a dangerous condition was when the purchaser added, aftermarket and from a third party, a Ford seat belt extender made for the front seat of a Ford Focus, in violation of Nissan’s explicit warning never to use a seat belt extender to install a child restraint. These circumstances are more attenuated than those under which the Coffman majority declined to impose a manufacturer’s duty to warn under the TPLA.
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We also conclude that Coffman’s explicit holding that “under the TPLA, manufacturers have no duty to warn with respect to products manufactured and sold by others” applies to the facts of this action and to Plaintiff’s theory of Dorel’s liability. Coffman, 615 S.W.3d at 899. We do not read Coffman’s holdings to be limited to cases about the post-sale integration of asbestos laden component parts, as Plaintiff suggests. Based on Coffman’s guidance and the relevant TPLA provisions, we have determined that Dorel did not owe Plaintiff a legal duty to warn about another manufacturer’s product under the circumstances of this case. The existence of a legal duty is an essential element of a failure to warn claim under the TPLA. Therefore, Dorel is entitled to summary judgment on Plaintiff’s failure to warn claim asserted in her fourth amended complaint.
Dorel, 2024 WL 2738197, at *8. Thus, the Court of Appeals interpreted Coffman broadly, as barring any failure-to-warn claim where the manufacturer’s original product is used in
We agree that there are facial similarities between Coffman and the instant case, in that both involve failure-to-warn claims in the context of a purchaser’s use of the defendant’s product with another product. But there are significant differences as well. Importantly, Coffman involved the end-consumer’s post-sale integration of another manufacturer’s asbestos-containing product into the equipment manufacturers’ non-dangerous product, to create a new “end-product.” Coffman, 615 S.W.3d at 894. In contrast, here, the end-consumer used two sound end-products together.
Coffman reflects a particular factual subset of cases involving the combination of two products. There are numerous other subsets:
Some common contexts in which [combined product] cases arise include: (1) when completed products are used in conjunction with one another; (2) when a third-party manufacturer outfits an incomplete product with component parts post-sale; (3) when new parts replace old ones; and (4) when a manufacturer creates a “bare-metal” product, which is one without necessary insulation or packing that is added on at a later time, either by the bare-metal manufacturer itself or a third-party such as another manufacturer or buyer.
David Judd, Disentangling DeVries: A Manufacturer’s Duty to Warn Against the Dangers of Third-Party Products, 81 La. L. Rev. 217, 229 (2020).
Different factual circumstances may be governed by different principles on duty and liability.12 For example, this Court has recognized some circumstances in which the TPLA may impose liability on the manufacturer of a component part for a defective final product. Davis v. Komatsu Am. Indus. Corp., 42 S.W.3d 34, 42–43 (Tenn. 2001) (citing
While this Court has not previously considered the type of claim at issue here, other jurisdictions have. Several treat claims like those in Coffman—where the end-consumer
Against that backdrop, we note that Coffman itself cautioned that its holding was limited, addressing only “[w]hether there is a duty to warn of the dangers associated with the post-sale integration of asbestos-containing parts that are manufactured and sold by others.” Coffman, 615 S.W.3d at 894. Later, Coffman cautioned “[a]gain” that it dealt “strictly” with “situations where there was post-sale integration of asbestos-containing parts manufactured and sold by others.”14 Id. at 897.
Factual differences between Coffman and the instant case could be material to the defendant’s duty to warn. In Coffman, the injuries were allegedly caused by asbestos. But
But here, neither product is inherently dangerous on its own. It is generally undisputed that both the Ford seat belt extender and the Dorel booster seat are sound products when used independently for their intended purposes. The Plaintiff here alleges that the end-consumer’s use of two sound and distinct products together creates a dangerous condition—a risk of harm that neither product poses on its own. Under the Plaintiff’s theory of the case, both the seat belt extender and the booster seat contributed to Ethan’s injuries. Both defendants allegedly failed to warn of the foreseeable dangers of their combined use.
Unlike in Coffman, the Plaintiff here alleges that the injuries resulted from foreseeable misuse of Dorel’s own product, the booster seat.15 The Plaintiff’s theory of liability is that the owner’s manual for the booster seat did not adequately warn of a misuse that was foreseeable to Dorel when the booster seat left Dorel’s control. And Dorel points to no language in the TPLA that relieves Dorel of a duty to warn simply because the foreseeable misuse of its product involves another manufacturer’s product as well.16
Thus, the Plaintiff’s claims in this case differ significantly from those in Coffman, and those differences may be material to the duty analysis. For example, a duty to warn might exist if it was foreseeable when the product left Dorel’s control that Dorel’s product would be used in combination with another product in a way that rendered Dorel’s product unsafe or unreasonably dangerous. See
To be clear, we are not holding that Dorel had a duty to warn consumers not to use its booster seat with Ford’s seatbelt extender. That issue is separate from the question before us in this appeal. Here, we are asked to clarify “whether Coffman . . . defeats Plaintiff’s claim against Dorel for failing to warn of the dangers associated with using a seatbelt extender to install the subject booster seat.” We hold it does not.
Accordingly, we conclude that the trial court and the Court of Appeals erred in holding that Coffman controls the outcome of this case.
Other Issues
In its brief, Dorel discusses alternative bases for granting it summary judgment that were pretermitted by the Court of Appeals’ holding that Coffman barred the Plaintiff’s claim.17 These alternative arguments were not included in the Court’s order granting
The parties’ appellate briefs include arguments on other issues that may be relevant to questions of duty or liability, such as whether booster seats can be safely used with seatbelt extenders, the adequacy of the warnings, the mechanics of Ethan’s injuries, and the legal effect of the warnings in the Nissan Juke manual. We decline to address these arguments or opine on whether Dorel had a duty to warn based on the circumstances of this case. Our ruling is limited to the narrow question of whether Coffman defeats Ms. Woodruff’s claim against Dorel. For the reasons explained above, we hold that it does not.
Accordingly, we remand this case to the Court of Appeals for further proceedings consistent with this Opinion.
CONCLUSION
We hold that this Court’s holding in Coffman v. Armstrong International, Inc., 615 S.W.3d 888 (Tenn. 2021), does not mandate dismissal as a matter of law of the Plaintiff’s failure-to-warn claim against defendant Dorel. Accordingly, we reverse the judgment of the Court of Appeals and remand this case to the Court of Appeals to consider pretermitted issues and any other proceedings not inconsistent with this Opinion.
s/Holly Kirby, Justice
HOLLY KIRBY, JUSTICE