Magaña v. Hyundai Motor America

On February 15, 1997, Ricky Smith (defendant), Angela Smith (defendant), and Jesse Magaña (plaintiff) were traveling in a 1996 Hyundai Accent when they collided with an oncoming truck driven by Dennis Nylander (defendant). Magaña was thrown from the rear window of the car and became a paraplegic due to his injuries. Magaña subsequently sued the Smiths, Nylander, and Hyundai Motor America and Hyundai Motor Company (collectively, Hyundai) (defendant) in Clark County Superior Court. Magaña alleged that his injuries were proximately caused by a design defect in the seat-back of the vehicle that caused the seat to collapse. During discovery, Magaña requested that Hyundai produce information relating to any other similar seat-back failures on any Hyundai products for the years 1980 to present. Hyundai responded that the request was overly broad, adding that there were no personal-injury or fatality lawsuits in connection with such incidents. Magaña also requested that Hyundai identify other Hyundai vehicles that had substantially similar front-right-seat designs. Hyundai responded that only the 1995-1999 Accents used a similar design. Magaña prevailed at trial, and a retrial was held to determine the respective liabilities between the Smiths and Hyundai. During this phase, it became clear that Hyundai had failed to disclose information related to other seat-back failures and that the Hyundai Elantra used a similar seat design. Magaña moved for default judgment based on the discovery misconduct. The trial court ruled in Magaña’s favor, finding (1) there was no agreement between the parties to narrow discovery; (2) Hyundai falsely responded to discovery requests; (3) Magaña was prejudiced by Hyundai’s misconduct; and (4) evidence was spoiled and lost forever. Accordingly, after considering lesser sanctions such as a monetary fine, the trial court imposed a default judgment against Hyundai. The court of appeals reversed the trial court, agreeing with the trial court that Hyundai willfully violated the discovery requests but finding that Magaña suffered no prejudice. The Washington Supreme Court granted review.