Sigler v. American Honda Motor Co.

Shelly Sigler (plaintiff) suffered a seizure as she was driving on a freeway in Tennessee in her Honda Accord. A witness stated that the Accord was driving about 70 miles per hour when it left the road and plunged down an embankment. The witness did not see any brake lights. The car struck a small tree hard enough to uproot it. The Accord’s airbag failed to inflate. Sigler was injured, and the car was declared a total loss. Sigler sued American Honda Motor Company (Honda) (defendant) in federal district court, alleging that the airbag was defective. Under Tennessee law, to establish a prima facie case that a product was defective, a plaintiff first needed to show that the product was defective. Under the consumer-expectation test, a plaintiff could establish that a product was defective by showing that the product fell below the reasonable minimum safety expectations of an ordinary consumer with ordinary knowledge of the product’s characteristics. The plaintiff was required to show that consumers were sufficiently familiar with the product to allow them to form reasonable expectations of its safety. Sigler offered evidence that consumers were familiar with airbags and had formed expectations about airbag performance. Sigler testified that she would have expected the airbag to deploy and produced a Honda brochure stating that the airbag would deploy in a crash over 30 miles per hour. Honda argued that the consumer-expectation test should not be applied to complex products like airbags. Honda also argued that the airbag did not deploy because the collision was low-speed. Honda brought a motion for summary judgment, arguing that Sigler’s evidence was insufficient to claim a genuine issue of material fact as to the existence of a defect in the airbag. The trial court granted Honda’s motion, and Sigler appealed.