Morgen v. Ford Motor Co.
Indiana Supreme Court
797 N.E.2d 1146 (2003)
Facts
Monterey Morgen (plaintiff) was sitting in the back of a car manufactured by Ford Motor Company (Ford) (defendant) when the car was hit and crashed into the vehicle in front of it. Morgen, who was not wearing a seatbelt, sustained a spinal-cord injury and became quadriplegic. Morgen brought a strict-products-liability action against Ford. Ford maintained that Morgen’s failure to wear a seatbelt constituted a misuse of the car. The trial court instructed the jury that in a strict-products-liability action, it was a defense that a cause of the plaintiff’s injury was product misuse that the seller did not reasonably expect when the product was sold. The jury found for Ford. The court of appeals reversed, ruling that the trial court erroneously gave a misuse instruction. The court stated that it had repeatedly held that it was foreseeable that a passenger might not wear a seatbelt, backseat passengers were not legally required to wear seatbelts, and, therefore, failure to wear a seatbelt could not constitute misuse. The Indiana Supreme Court granted transfer. Morgen argued that his failure to wear a seatbelt did not constitute a misuse as a matter of law, and Ford argued that the question of misuse was for the jury to decide.
Rule of Law
Issue
Holding and Reasoning (Sullivan, J.)
Dissent (Rucker, J.)
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