Benavides v. Tesla, Inc.

George McGee (defendant) owned a 2019 Tesla Model S, which had an autopilot system. One day, McGee dropped his cell phone while driving on a two-lane country road. When McGee reached down to pick up the phone, he ran a stop sign going 65 miles per hour, crashing into a parked Chevy Tahoe and pushing it into two pedestrians, Dillon Angulo (plaintiff) and Naibel Benavides Leon. Angulo suffered severe injuries, and Leon died. The vehicle’s autopilot system had detected the stop sign, the parked car, and one of the pedestrians but failed to alert McGee or engage the vehicle’s brakes. Leon’s estate (plaintiff) and Angulo sued McGee and Tesla, Inc. (defendant), asserting various claims, including strict-products-liability claims against Tesla for design defects and failure to warn. The design-defect claim was based on expert opinions attesting to three alleged defects: (1) that the driver-monitoring system deactivated autopilot if a driver took his hands off the wheel too long but allowed the driver to immediately reengage autopilot by putting the vehicle in park and shifting back into drive; (2) that autopilot was designed to operate on divided, limited-access highways only but could be activated on any road with lane markings; (3) that autopilot failed to alert McGee or apply the brakes upon detecting obstacles, including a pedestrian. The failure-to-warn claim alleged that Tesla failed to provide adequate warnings about the dangers of using and relying on autopilot. Tesla moved for summary judgment on the design-defect and failure-to-warn claims. For the design-defect claim, Tesla argued McGee alone caused the collision. For the failure-to-warn claim, Tesla argued that it provided adequate warnings regarding the autopilot system in the vehicle’s owner’s manual and via on-screen prompts upon autopilot activation telling drivers to keep their hands on the steering wheel and be prepared to override autopilot at any time.