Burgos v. Lutz
New York Supreme Court, Appellate Division
128 A.D.2d 815 (N.Y. App. Div. 1987)
The plaintiff's decedent died when a car accident caused the steering column to strike his chest; the plaintiff sued Honda (defendant), alleging defective design of both the seat-belt system and the steering column. The plaintiff's expert testified the seat belt's locking mechanism operated erratically but never established the erratic behavior stemmed from the mechanism's design, offered no feasible safer alternative design, and the plaintiff never even established the decedent was wearing his seat belt at the time of the crash; a separate expert proposed an alternative steering-column design but never testified that design would actually have prevented the decedent's injuries. The trial court granted Honda's motion to dismiss the design-defect claims, and the plaintiff appealed.
Whether a plaintiff asserting a design-defect claim must demonstrate that a defect in the defendant's product actually caused the injury suffered.