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General Motors Corp. v. Superior Court

California Court of Appeal

48 Cal. App. 4th 580, 55 Cal. Rptr. 2d 871 (1996)

Facts

Susanna Jeffrey (plaintiff) was injured when her Chevrolet Blazer was rear-ended. Jeffrey’s face hit the steering wheel even though she was wearing her seat belt. Jeffrey sued the other driver and 20 Doe defendants. About 17 months later, Jeffrey’s lawyer brought on more experienced counsel, who filed an amended complaint adding a products liability claim against General Motors (GM) (defendant), alleging that the seat belt in Jeffrey’s Blazer was defectively designed. GM moved to quash service on grounds that Jeffrey must have known she had a potential claim against GM when she filed her original claim because she previously told her doctor that her face hit the steering wheel in the accident because the seat belt did not hold her, and it is a known fact immediately after an accident whether a seat belt restrained a passenger or not. Jeffrey countered that despite knowing that GM manufactured her car when she filed her original complaint, she did not learn that the seat belt’s comfort-feature design was most likely the cause of her injuries. The trial court denied GM’s motion, and GM appealed.

Rule of Law

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Issue

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Holding and Reasoning (Vogel, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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