Whitehead v. Toyota Motor Corp.

Whitehead (plaintiff) crossed the centerline and collided with another vehicle, then sued Toyota (defendant) for strict products liability, claiming a defective seatbelt design enhanced his injuries; Toyota sought to introduce comparative-fault evidence to reduce recovery. Tennessee courts had not addressed whether comparative fault applied to strict-liability claims, and a federal district court certified two questions to the Tennessee Supreme Court: whether comparative fault applies to strict products liability generally, and whether it applies specifically to enhanced-injury claims.

Whether, under the majority view, comparative fault may be used as a defense to a products-liability claim based on strict liability, including in enhanced-injury cases.