Hyundai Motor Co. v. Duncan

CourtSupreme Court of Virginia
DecidedJanuary 8, 2015
Docket140216
StatusPublished

This text of Hyundai Motor Co. v. Duncan (Hyundai Motor Co. v. Duncan) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hyundai Motor Co. v. Duncan, (Va. 2015).

Opinion

PRESENT: Lemons, C.J., Millette, Mims, McClanahan, and Powell, JJ., and Russell and Lacy, S.JJ.

HYUNDAI MOTOR COMPANY, LTD., ET AL. OPINION BY v. Record No. 140216 JUSTICE ELIZABETH A. McCLANAHAN JANUARY 8, 2015 KEITH ALLEN DUNCAN, INDIVIDUALLY AND AS GUARDIAN AND CONSERVATOR FOR ZACHARY GAGE DUNCAN, ET AL.

FROM THE CIRCUIT COURT OF PULASKI COUNTY Colin R. Gibb, Judge

In this products liability action, Hyundai Motor Company,

Ltd., and Hyundai Motor America, Inc. (Hyundai) appeal from a

judgment entered on a jury verdict in favor of Keith Allen

Duncan and Vanessa Duncan, Guardians and Conservators for

Zachary Gage Duncan (Gage), and Keith Allen Duncan and Vanessa

Duncan, Individually.1 Hyundai contends the circuit court erred

in admitting the opinion testimony of the Duncans' designated

expert witness, who testified that the location of the side

airbag sensor in the 2008 Hyundai Tiburon being driven by Gage

when he sustained injuries in a single-vehicle accident

rendered the Tiburon unreasonably dangerous. We agree and will

reverse the judgment of the circuit court.

1 The jury was unable to reach a verdict when the case was first tried in 2012. After the case was retried in 2013, the jury returned a verdict for the Duncans in the amount of $14,140,000. I. BACKGROUND

Gage sustained a serious closed-head injury while driving

his 2008 Hyundai Tiburon when he lost control of the vehicle,

causing the vehicle to leave the road, strike two snow banks

and a large bale of hay, before ultimately colliding with a

tree on the driver's side of the vehicle. Although the Tiburon

was equipped with a side airbag system, the airbag did not

deploy.

The Duncans brought an action against Hyundai, which

manufactured and distributed the 2008 Tiburon being driven by

Gage, and initially asserted claims for negligence, failure to

warn, breach of implied warranty of merchantability, breach of

implied warranty of fitness for a particular purpose, and

breach of express warranties. At trial, the Duncans pursued

only their claim for breach of implied warranty of

merchantability in which they assert that the "Tiburon was

defective, unreasonably dangerous, was not fit for the ordinary

purpose for which it was intended, and did not pass without

objection in the industry in which it was sold." Specifically,

the Duncans contend that if the sensor for the side airbag

system had been placed in a different location, the airbag

would have deployed and prevented Gage's injury.

2 II. Expert Testimony of Design Defect

To support their claim, the Duncans designated Geoffrey

Mahon (Mahon), a mechanical engineer, as an expert in airbag

design to testify that the 2008 Hyundai Tiburon was defectively

designed. Mahon expressed the opinion that if Hyundai had

located the sensor for the side airbag system on the B-pillar

of the vehicle (the pillar where the front door closes),

approximately 4 to 6 inches from the floor, instead of on the

cross-member underneath the driver's seat, the side airbag

would have deployed. Therefore, according to Mahon, the

location of the side airbag sensor on the cross-member rendered

the 2008 Tiburon unreasonably dangerous.

A. Motion in Limine

Prior to trial, Hyundai moved to exclude Mahon's opinions

as having an insufficient foundation because Mahon did not

conduct any analysis to determine whether the side airbag would

have deployed if the sensor had been located where Mahon

proposed.

When deposed, Mahon testified that in reaching his

opinion, he relied upon a computer-aided engineering study

conducted by Hyundai in 1999 in which Hyundai analyzed 14

potential locations for the side airbag sensor, including a

location on the B-pillar that was 10 to 12 inches from the

3 floor.2 Mahon did not adopt any of the 14 locations analyzed by

Hyundai for his placement of the side airbag sensor, but

determined that a location on the B-pillar approximately 4 to 6

inches from the floor "would be [his] first choice." He

further explained that since Hyundai did not analyze the

location he proposed, he would "have to run tests to verify

that that's just the right location, but based on [Hyundai's]

evidence of the somewhat higher B-pillar location, that looks

very promising."

While Mahon believed the best location for the sensor was

at the B-pillar, he testified he did no testing to determine if

the side airbag would have deployed in Gage's accident had the

sensor been placed at any other location.

Q . . . Have you done any test or calculation to show that some other sensing system location if used in the Duncan Tiburon would have caused the side air bag to fire in this crash?

A I have not done any tests, I think as I indicated earlier, nor have I done any serious calculations. What I've done is look at the signal at the B-pillar and the signal at the location and concluded that I got a much more robust and timely signal at the B-pillar.

(Emphasis added.) The circuit court denied Hyundai's motion to exclude Mahon's testimony, and he was permitted

2 Based on the 1999 location study and subsequent crash testing, Hyundai decided to place the sensor on the cross- member underneath the driver's seat. 4 to express his opinions at trial, over Hyundai's objections.3

B. Trial Testimony

At trial, Mahon testified that Hyundai was not required

under Federal Motor Vehicle Safety Standards (FMVSS) to install

a side-impact airbag system in the 2008 Tiburon, and that the

2008 Tiburon would have complied with the FMVSS for side impact 4 protection without any side airbag system. Nevertheless,

according to Mahon, if a manufacturer decides to put in an

airbag system and "tell people there's a safety system in this

car that's going to work a certain way and then it doesn't

work? It's got to work. I mean, that's just improper."

Mahon's initial impression of the airbag system was that

"the airbag should have gone off," but upon further

investigation, he concluded that the system was acting as

designed "so this indicates that it was designed improperly,

because this is a crash where you really need an airbag."

Mahon agreed that the 2008 Tiburon, with the side airbag

system, complied with FMVSS 214, the standard specifically

3 The circuit court ruled on Hyundai's motion to exclude Mahon's opinion prior to the first trial and adopted its ruling prior to the second trial. 4 As Mahon explained, the National Highway Traffic Safety Administration is responsible for regulating the safety performance of motor vehicles and has established the FMVSS as minimum standards with which all vehicles sold in the United States must comply. 5 related to side impact protection. He further acknowledged

that the 2008 Tiburon "did reasonably well" when Hyundai

conducted 22 crash tests in which it ran the vehicle into

different types of barriers, at different speeds and angles,

with the side airbag sensor located on the cross-member

underneath the driver's seat.5

In Mahon's opinion, however, the side airbag would have

deployed in Gage's accident if the sensor for the side airbag

system had been located on the B-pillar, approximately 4 to 6

inches from the floor.

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