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Quintana-Ruiz v. Hyundai Motor Corp.

United States Court of Appeals for the First Circuit
303 F.3d 62 (2002)


Ines Reyes-Quintana was riding in the passenger seat of a car manufactured by Hyundai Motor Corporation (Hyundai) (defendant), when the car rear-ended the car in front of it at a speed differential of 30 miles per hour. The passenger-side airbag in the Hyundai deployed, breaking Reyes-Quintana’s arm. Evidence indicated that Reyes-Quintana was wearing a seat belt at the time. Quintana-Ruiz (plaintiff), Reyes-Quintana’s mother, brought a design-defect suit against Hyundai on Reyes-Quintana’s behalf. Quintana-Ruiz argued that the airbag should have been designed to deploy only at a higher barrier equivalent velocity (BEV), which is the speed at which a car hits another object. In effect, Quintana-Ruiz argued that Reyes-Quintana would not have incurred as grievous an injury if the airbag had not deployed. During trial, Hyundai presented expert testimony that, if the airbags had been designed to deploy at a higher BEV, there would be many accidents in which individuals would be seriously injured due to the airbags’ failure to deploy, particularly in the case of individuals who were not wearing seat belts. Federal law required that airbags be designed to protect individuals, regardless of whether they are wearing seat belts. Experts also testified that, although airbags may have caused injuries, they have also saved thousands of lives. Hyundai conceded that Quintana-Ruiz met her burden of establishing that the airbag’s design was the proximate cause of the injury but argued that the benefits of the design of the airbags outweighed the risk of danger inherent in the design. The jury found in favor Quintana-Ruiz, and Hyundai appealed.

Rule of Law


Holding and Reasoning (Lynch, J.)

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