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Piltch v. Ford Motor Co.
United States Court of Appeals for the Seventh Circuit
778 F.3d 628 (2015)
Howard Piltch and Barbara Nelson-Piltch (the Piltches) (plaintiffs) owned a car manufactured by Ford Motor Company (Ford) (defendant). The Piltches were in an accident, and the airbags failed to deploy. The car was repaired, and Howard believed that the device that controlled the airbag deployment had been reset. While traveling in the car a year later, the Piltches hit black ice and slid off the road into a wall. The airbags did not deploy. The Piltches sold the car, and the buyer reprogrammed the car’s black box. The Piltches subsequently brought an action against Ford, alleging that the car was defective. Ford moved for summary judgment. In opposing summary judgment, the Piltches presented the car’s owner’s manual, which stated that the airbags were designed to deploy when the car sustained “sufficient longitudinal deceleration.” The Piltches also offered Howard’s testimony about the state of the airbags before and after the second collision. No expert testimony was offered. The court granted Ford’s summary-judgment motion. The Piltches appealed, arguing that the car owner’s manual and Howard’s testimony were sufficient to create a genuine issue of material fact as to the existence of a manufacturing defect.
Rule of Law
Holding and Reasoning (Bauer, J.)
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