Clark v. Chrysler Corp.

When Charles Clark’s truck collided with an oncoming vehicle, Charles was ejected from the truck and died. Charles’s wife, Dorothy Clark (plaintiff) sued Chrysler Corp. (defendant), the truck’s manufacturer, on strict-liability, negligence, and failure-to-warn theories. Dorothy presented evidence that the “unboxed” design of the truck’s door latch and frame was outdated, weak, and a known industry failure; Chrysler did not test for latch failures; and Chrysler knew the death risk increased if a driver was ejected. No evidence was presented that a “boxed” design would have prevented Charles’s injuries, and the necessity of testing was disputed. The jury found Chrysler and Charles each 50 percent at fault and awarded compensatory damages of $471,000 and punitive damages of $3,000,000. The court entered a judgment against Chrysler for one-half the compensatory damages and $3,000,000 in punitive damages. The Sixth Circuit upheld the awards. The statutory penalties for a design defect were $1,000 per vehicle and up to $800,000 for serial violations. Chrysler petitioned for certiorari after the State Farm Mutual Automobile Insurance Co. v. Campbell decision. The Supreme Court vacated the judgment and remanded for further consideration in light of State Farm. The district court upheld the award and denied Chrysler’s motions for remittitur and other relief. Chrysler appealed.