Muth v. Ford Motor Company
United States Court of Appeals for the Fifth Circuit
461 F.3d 557 (2006)
- Written by Joe Cox, JD
Facts
Barry Muth (plaintiff) was a major in the United States Army and riding in a 1996 Ford Crown Victoria when the driver of the vehicle lost control and ran into a three-foot barrier separating the sides of the highway. The left front wheel climbed that barrier, and the car flipped, coming to rest on its roof 209 feet from the initial impact. Muth suffered a spinal injury and was rendered quadriplegic due to the accident. Muth and his family sued Ford (defendant), arguing negligence and strict product-liability claims. Specifically, Muth argued that Ford built an inadequate occupant-restraint system into the vehicle. Muth’s expert witness testified that the roof collapsed 12 to 15 inches on the passenger side and that Ford could have used thicker steel and reduced the roof collapse to 3 inches for just $9 per car. Ford did not dispute this argument but argued that a stronger roof would have no real effect in rollover accidents. This argument was premised on the idea that in a rollover accident, a normal seatbelt allows the body to drop five inches toward the roof, which is more than the three to four inches of clearance between the passenger’s head and the roof. Only a NASCAR-style harness seatbelt, Ford argued, could be safer. Ford used data from two crash tests—an early 1980s test from General Motors involving Chevy Malibu sedans and a 2000 to 2001 test from Ford that studied the Controlled Rollover Impact System. Both tests studied rollover accidents similar to what Ford contended had occurred in the subject accident but notably different from Muth’s evidence of how the accident occurred. Although the court allowed Ford’s experts to testify about these tests, Ford was prohibited from using video and photographic evidence to illustrate the test data. At trial, a jury found that the Crown Victoria had a design defect that was a producing cause of Muth’s injury. Muth then received a judgment for $9 million, and Ford appealed.
Rule of Law
Issue
Holding and Reasoning (Higginbotham, J.)
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