Olson v. Ford Motor Co.

558 N.W.2d 491, 1997 Minn. LEXIS 78, 1997 WL 58704
CourtSupreme Court of Minnesota
DecidedFebruary 13, 1997
DocketC5-96-915
StatusPublished
Cited by61 cases

This text of 558 N.W.2d 491 (Olson v. Ford Motor Co.) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Olson v. Ford Motor Co., 558 N.W.2d 491, 1997 Minn. LEXIS 78, 1997 WL 58704 (Mich. 1997).

Opinions

OPINION

KEITH, Chief Justice.

This case comes to us on an Order of Certification issued by the United States District Court for the District of Minnesota pursuant to Minn.Stat. § 480.061 (1996) (Uniform Certification of Questions of Law Act). The certified question is as follows:

Does Minn.Stat. § 169.685, subd. 4, bar the introduction of evidence of the plaintiffs personal seat belt use in a crashworthiness action alleging the seat belt, itself, was negligently designed or manufactured?

We answer the question in the affirmative.

I.

On December 30, 1993, Kyle Olson was injured when the 1985 Ford F-150 truck that he was driving collided with another vehicle on Minnesota Highway 29. Olson claims he was wearing a factory-installed seat belt at the time of the collision and that the seat belt failed, materially contributing to his injuries.

Olson brought suit in Mower County District Court against Ford Motor Company, manufacturer of the truck. He alleged that the truck was not “crashworthy” because of the defective seat belt restraint system and sought recovery under theories of strict liability, negligence, and breach of warranty. After successfully removing the case to federal district court, Ford filed a motion for summary judgment on all counts. Ford argued that summary judgment was appropriate because evidence of Olson’s alleged use of the truck’s seat belts would be inadmissible at trial under Minn.Stat. § 169.685, subd. 4— known as the “seat belt gag rule.”

In considering Ford’s motion, the federal district court determined that its resolution of this issue would require a definitive interpretation of the state gag rule law. Accordingly, the federal district court certified the question before this court.

Olson raises essentially the same arguments against application of the seat belt gag rule in this case as were unsuccessfully raised before the Minnesota Court of Appeals this past year by the plaintiff in Anker v. Little, 541 N.W.2d 333, 340 (Minn.App[494]*494.1995), pet. for rev. denied (Minn. Feb. 9, 1996). Olson criticizes the result in Anker, and challenges the application of the seat belt gag rule in this case both on statutory and constitutional grounds.1 He contends: (1) that by its plain language, Minn.Stat. § 169.685, subd. 4, does not apply to crash-worthiness cases; (2) that interpreting the seat belt gag rule to bar a plaintiffs crash-worthiness action for a defective seat belt produces an absurd result, not contemplated by the legislature; and, finally, (8) that such an interpretation of the statute would be violative of both the federal and state constitutions.

II.

This case requires us to determine whether Minnesota’s seat belt gag rule bars seat belt evidence when a plaintiffs cause of action is predicated on the failure of the seat belt itself under the crashworthiness doctrine.2

When interpreting a statute, our function is to ascertain and effectuate the intention of the legislature. Minn.Stat. § 645.16 (1996). If the statute is free from all ambiguity, we look only to its plain language. Id.; Tuma v. Commissioner of Econ. Sec., 386 N.W.2d 702, 706 (Minn.1986). When, however, the literal meaning of the words of a statute would produce an absurd result, we have recognized our obligation to look beyond the statutory language to other indicia of legislative intent. Wegener v. Commissioner of Revemte, 505 N.W.2d 612, 617 (Minn.1993); see Minn.Stat. § 645.17(1).

The seat belt gag rule, Minn.Stat. § 169.685, subd. 4, specifically provides:

Proof of the use or failure to use seat belts or a child passenger restraint system as described in subdivision 5, or proof of the installation or failure of installation of seat belts or a child passenger restraint system as described in subdivision 5 shall not be admissible in evidence in any litigation involving personal injuries or property damage resulting from the use or operation of any motor vehicle.

In Anker, the court of appeals determined that “[t]his language is unambiguous in prohibiting the admission of evidence of the use or nonuse of seat belts in any litigation involving personal injury that results from the use or operation of a motor vehicle.” 541 N.W.2d at 336. We agree.

We find Olson’s contention that crashworthiness claims fall outside the ambit of the seat belt gag rule unpersuasive. On its face, the statute bars evidence of seat belt use or nonuse in “any litigation * * * resulting from the use or operation of any motor vehicle.” Minn.Stat. § 169.685, subd. 4 (emphasis added). This broad statutory preclusion is in no way limited to injuries directly attributable to the act or defect actually causing a motor vehicle accident, but instead manifestly extends to all injuries resulting from the same accident. See Swelbar v. Lahti, 473 N.W.2d 77, 79 (Minn.App.1991) (“[T]he statute unambiguously bars evidence of use or nonuse of seat belts or child restraints in any litigation ‘involving’ personal injury resulting from the use of a motor vehicle.”); Wilson v. Volkswagen of America, Inc., 445 F.Supp. 1368, 1374 (E.D.Va.1978) (contrasting 'Virginia’s narrow gag rule statute to Minnesota’s, which the court found precludes seat belt evidence “for any purpose whatsoever.”).

Absent some other justification allowing us to consider legislative intent, we need look no further than the express language of the statute. Tuma, 386 N.W.2d at 706. As prescribed in Minn.Stat. § 645.16, “When the words of a law in their application to an existing situation are clear and free from all ambiguity, the letter of the law shall not be disregarded under the pretext of pursuing the spirit.” Christopherson v. Federal Land [495]*495Bank of St. Paul, 388 N.W.2d 373, 374 (Minn.1986) (“Here, the language of the statute is precise and unambiguous and we must give the effect to the statute as written.”).

III.

Olson argues that even if we determine that the plain language of the statute applies to crashworthiness claims, this court must consider other indicia of legislative intent in order to avoid an “absurd” result. See Minn.Stat. § 645.17(1) (establishing a presumption in ascertaining legislative intent that “[t]he legislature does not intend a result that is absurd, impossible of execution, or unreasonable”); see also Glyn-Jones v. Bridgestone/Firestone, Inc., 857 S.W.2d 640, 643-44 (Tex.Ct.App.1993) (holding that barring evidence of a defective seat belt would be “arbitrary and unreasonable” in light of the Texas statute’s stated purpose of promote ing safety on public highways through mandatory seat belt use), ajfd on other grounds, 878 S.W.2d 132, 133-34 (Tex.1994). We will only exercise our power to undertake such an expanded inquiry when a party demonstrates that the statute’s plain language utterly departs from a clearly expressed goal of the legislature. See Wegener,

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Bluebook (online)
558 N.W.2d 491, 1997 Minn. LEXIS 78, 1997 WL 58704, Counsel Stack Legal Research, https://law.counselstack.com/opinion/olson-v-ford-motor-co-minn-1997.