Soule (plaintiff) was driving her 1982 Camaro when she was struck by another vehicle near the left wheel of her car. The collision bent the Camaro’s frame and tore loose the bracket that attached the car’s wheel assembly to the frame. The wheel collapsed inward and hit the underside of the “toe pan,” the slanted floorboard area beneath the pedals, causing it to crumple. Soule sustained permanent injuries to both of her ankles. After the collision, the Camaro was purchased by a salvage dealer, and except for the bracket assembly, no part of the vehicle was retained as evidence. Soule sued General Motors Corporation (GM) (defendant) alleging that a defective design of the Camaro allowed the left front wheel to break free and smash the floorboard into Soule’s feet and ankles. At trial, the jury was instructed that in order to impose liability upon GM, Soule was required to show that the Camaro failed to perform as safely as an ordinary consumer would expect. The jury found for Soule and awarded $1.65 million in damages. GM appealed and argued that the trial court erred in instructing the jury on the “ordinary consumer expectations in a complex design-defect case.” The court of appeals affirmed the jury’s verdict, and GM appealed.