Sarah Elizabeth Woodruff v. Ford Motor Company

In this interlocutory appeal, we hold that this Court’s holding in Coffman v. Armstrong International, Inc., 615 S.W.3d 888 (Tenn. 2021), does not mandate dismissal as a matter of law of the plaintiff’s failure-to-warn claims. Here, the plaintiff filed a product liability lawsuit under the Tennessee Products Liability Act against the defendant alleged manufacturer of a seatbelt extender. The lawsuit claimed that the defendant was required to warn of risks of using the seatbelt extender in combination with a child’s booster seat, manufactured by another defendant, but the defendant failed to do so. After a mistrial, the trial court granted permission for interlocutory appeal on the question of whether Coffman bars the plaintiff’s failure-to-warn claims for risks associated with using the defendant’s product with another manufacturer’s product. The Court of Appeals granted the interlocutory appeal and held that Coffman bars the plaintiff’s claims as a matter of law. We reverse the Court of Appeals and clarify that the holding in Coffman does not mandate dismissal of the plaintiff’s failure-to-warn claims as a matter of law. Accordingly, we reverse the judgment of the Court of Appeals and remand the case to the trial court for further proceedings.