Mikolajczyk v. Ford Motor Company
Supreme Court of Illinois
901 N.E.2d 329 (2008)
James Mikolajczyk (plaintiff) died of severe brain injury after a drunk driver rear-ended his stopped Ford Escort at 60 miles per hour, collapsing the Escort's driver's seat and causing him to strike his head on the backseat. His estate sued Ford Motor Company and Mazda Motor Corporation (defendants), the manufacturers of the car and its seat, presenting competing evidence on the risks and benefits of collapsible versus rigid car seats; the trial court instructed the jury using the standard "unreasonably dangerous" definition from the Illinois Pattern Jury Instructions rather than a risk-utility instruction the manufacturers requested, and the jury awarded $27 million. Ford and Mazda appealed, arguing that for a complex product like a yielding car seat, the jury should have been instructed using a risk-utility test rather than what they characterized as a consumer-expectation test better suited to simpler products.
Whether the risk-utility test is the test for whether a defendant is strictly liable for a design defect.