Quintana-Ruiz v. Hyundai Motor Corp.
United States Court of Appeals for the First Circuit
303 F.3d 62 (2002)
A passenger-side airbag in a Hyundai (defendant) broke Reyes-Quintana's arm when it deployed during a rear-end collision at a 30 mph speed differential while she wore her seatbelt; her mother (plaintiff) sued arguing the airbag should have deployed only at a higher barrier-equivalent velocity, and Hyundai's experts testified that federal law required protecting occupants regardless of seatbelt use and that a higher deployment threshold would leave many unbelted occupants without protection in serious crashes, even though airbags overall save many lives despite occasionally causing injuries.
Whether, under products-liability law, if a plaintiff proves that a product's design is the proximate cause of the damage, the burden shifts to the defendant to prove that the benefits of the design outweigh the risk of danger inherent in the design.