Jahn v. Hyundai Motor Co.
Supreme Court of Iowa
773 N.W.2d 550 (2009)
Burke ran a stop sign and crashed into Jahn's (plaintiff) car, which was made by Hyundai (defendant); the car's airbags failed to deploy, and Jahn suffered serious injuries. Jahn settled with and released Burke, then sued Hyundai, alleging the defective airbags enhanced his injuries beyond what the crash alone would have caused. Hyundai argued Burke's negligence was the proximate cause and that her fault should be compared against Hyundai's own. The federal district court certified two questions to the Iowa Supreme Court: the applicable enhanced-injury standard, and whether comparative fault applies to a released third party's negligence in that context.
Whether, under products-liability law, a plaintiff can hold a manufacturer liable for a defect that did not cause the initial accident by showing the defect was a substantial factor in creating harm beyond that from the accident alone, and whether the fault of a released party whose negligence proximately caused the plaintiff's injuries may be compared with the manufacturer's fault in such an enhanced-injury claim.