Shaffer v. Toyota Motor Corporation

CourtDistrict Court, W.D. Oklahoma
DecidedFebruary 28, 2025
Docket5:22-cv-00151
StatusUnknown

This text of Shaffer v. Toyota Motor Corporation (Shaffer v. Toyota Motor Corporation) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shaffer v. Toyota Motor Corporation, (W.D. Okla. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF OKLAHOMA

NICK SHAFFER and CHARLA SHAFFER, ) Individually, and NICK and CHARLA ) SHAFFER, as Parents and Next Friends of ) HOPE SHAFFER, Deceased, ) ) Plaintiffs, ) ) v. ) No. CIV-22-151-R ) TOYOTA MOTOR CORPORATION; ) TOYOTA MOTOR NORTH AMERICA, ) INC.; TOYOTA MOTOR ENGINEERING ) & MANUFACTURING MISSISSIPPI, ) INC.; TOYOTA MOTOR SALES, USA, ) INC.; and GULF STATES TOYOTA, INC.; ) ) Defendants. )

ORDER Before the Court is Toyota Defendants’ Partial Motion for Summary Judgment [Doc. No. 116]. Plaintiffs Nick Shaffer and Charla Shaffer responded [Doc. No. 133], and Defendants replied [Doc. No. 140]. The matter is now at issue. For the following reasons, the Motion regarding Plaintiffs’ strict liability claim is GRANTED. Factual Background Hope Shaffer was killed in a car crash while being driven home from driver’s education training. She was sitting in the rear passenger seat of a 2020 Toyota Corolla while another student was driving and the instructor, George Voss, was sitting in the front passenger seat directly in front of her. When the student driver was attempting to exit from the highway, she became confused and came to a nearly complete stop on the off-ramp. The Corolla was rear-ended by a Chevrolet Silverado also attempting to exit the highway. While the student driver and Mr. Voss suffered only minor injuries from the collision, Ms.

Shaffer died from blunt force trauma to the front of her skull. What caused the trauma is disputed. Plaintiffs’ theory of the case is that Mr. Voss’s head collided with Ms. Shaffer’s head due to a defect in the front passenger seat of the subject Corolla [Doc. No. 133 at p. 1]. Specifically, Plaintiffs claim that the front seat was not rigid enough to prevent “ramping,”1 which can lead to passenger-on-passenger contact in severe collisions. Id.

Defendants’ theory is that Ms. Shaffer’s head hit a narrow, rigid object within the vehicle rather than Mr. Voss’s head. Accordingly, they contend that the seat was not defective, and that Mr. Voss did not ramp into the backseat. Plaintiffs brought suit in state court for (1) strict products liability and (2) common law negligence [Doc. No. 1-1 pp. 10-15]. They additionally sought punitive damages under

Oklahoma law. Id. at p. 15. Defendants removed the action to this Court [Doc. No. 1] and now seek partial summary judgment on Plaintiffs’ strict products liability claim, as well as their prayer for punitive damages. Doc. No. 116 at p. 1. Motion for Summary Judgment A. Legal Standard

Summary judgment is proper “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R.

1 “Ramping” occurs when a seat yields to the point that the seat becomes fully reclined [Doc. No. 116-4 at p. 7]. Civ. P. 56(a). Whether a fact is material is determined by the substantive law at issue, and “[o]nly disputes over facts that might affect the outcome of the suit under the governing

law will properly preclude the entry of summary judgment.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A dispute is genuine “if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Id. The movant “always bears the initial responsibility of…identifying those portions of the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, which it believes demonstrate the absence of a genuine issue of

material fact.” Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986) (quotation marks omitted). “If the movant carries this initial burden, the nonmovant that would bear the burden of persuasion at trial may not simply rest upon its pleadings; the burden shifts to the nonmovant to go beyond the pleadings and set forth specific facts that would be admissible in evidence in the event of trial from which a rational trier of fact could find for

the nonmovant.” Adler v. Wal-Mart Stores, Inc., 144 F.3d 664, 670 (10th Cir. 1998) (citation omitted). The Court “view[s] the evidence and draw[s] reasonable inferences therefrom in the light most favorable to the nonmoving party.” Sanders v. Sw. Bell Tel., L.P., 544 F.3d 1101, 1105 (10th Cir. 2008). At this stage, the Court’s role is not “to weigh the evidence and

determine the truth of the matter,” but to determine “whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law.” Anderson, 477 U.S. at 249-252. B. Strict Liability Defendants’ motion for summary judgment as to Plaintiffs’ strict liability claim is

premised on the rebuttable presumption of non-liability established in Okla. Stat. tit. 76, § 57.2(A): In a products liability action brought against a product manufacturer or seller, there is a rebuttable presumption that the product manufacturer or seller is not liable for any injury to a claimant caused by some aspect of the formulation, labeling, or design of a product if the product manufacturer or seller establishes that the formula, labeling, or design for the product complied with or exceeded mandatory safety standards or regulations adopted, promulgated, and required by the federal government, or an agency of the federal government, that were applicable to the product at the time of manufacture and that governed the product risk that allegedly caused harm.

Okla. Stat. tit. 76, § 57.2(A). This presumption may be rebutted by establishing that either: 1. The mandatory federal safety standards or regulations applicable to the product and asserted by the defendant as its basis for rebuttable presumption were inadequate to protect the public from unreasonable risks of injury or damage; or

2. The manufacturer, before or after marketing the product, withheld or misrepresented information or material relevant to the federal government’s or agency’s determination of adequacy of the safety standards or regulations at issue in the action.

Okla. Stat. tit. 76, § 57.2(B)(1)-(2). The parties agree that FMVSS 207 is the pertinent federal regulation at issue. Doc. No. 133 at n.1. It is likewise undisputed that the front seat of the subject Corolla complied with FMVSS 207 at the time of the collision. Id. at p. 5. Thus, the rebuttable presumption set forth in Okla. Stat. tit. 76, § 57.2(A) applies to this case. The overarching issue then is whether Plaintiffs can rebut that presumption using one of the two methods outlined in Okla. Stat. tit. 76, § 57.2(B)(1)-(2). The Oklahoma Supreme Court has not previously analyzed the presumption. Defendants’ invocation of the rebuttable presumption to challenge Plaintiffs’ strict liability

claim therefore presents a question of first impression.

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