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Mikolajczyk v. Ford Motor Company

901 N.E.2d 329 (2008)

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Mikolajczyk v. Ford Motor Company

Supreme Court of Illinois

901 N.E.2d 329 (2008)

Facts

William Timberlake (defendant) was inebriated when he rammed his Cadillac, at 60 miles per hour, into the rear of a Ford Escort stopped at a stoplight. On impact, the Escort’s driver’s seat collapsed, causing its driver, James Mikolajczyk (plaintiff), to hit his head on the backseat. Mikolajczyk suffered severe brain injury and died after spending several days on life support. Mikolajczyk’s estate sued the manufacturer of the car, Ford Motor Company (Ford) (defendant), the manufacturer of the driver’s seat, Mazda Motor Corporation (Mazda) (defendant), and Timberlake. The trial court entered summary judgment against Timberlake. The claims against Ford and Mazda went to a jury. At trial, the parties put forth evidence regarding the risks and benefits of collapsible, or “yielding” car seats, and the risks and benefits of rigid car seats. The trial court instructed the jury using, among other instructions, the definition of “unreasonably dangerous” under the Illinois Pattern Jury Instructions. Ford and Mazda objected to this instruction, arguing that instead the jury should have been given a risk-utility test in order to determine whether the driver’s seat was unreasonably dangerous because of a design defect. The trial court rejected Ford and Mazda’s jury instruction. The jury found that the driver’s seat was unreasonably dangerous, awarding $27 million in damages to Mikolajczyk’s estate. Ford and Mazda appealed, arguing that the trial court improperly instructed the jury. The court of appeals upheld the lower court’s judgment. Ford and Mazda appealed. On appeal, they described the instructions given to the jury as a consumer-expectation test, better suited to simple products with defects. They urged the court to adopt a risk-utility test for cases where the plaintiff alleges defective design in a complex product.

Rule of Law

Issue

Holding and Reasoning (Garman, J.)

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