The Tennessee Supreme Court held today that a prior product liability case does not require dismissal of a product liability lawsuit on a fatal accident involving the use of a seatbelt extender with a child’s booster seat.
In August 2013, plaintiff Sarah Woodruff’s husband, Benjamin Woodruff, was driving their family vehicle in Knoxville, with the couple’s two children in the back seat. A car driven by a drug-impaired driver struck the Woodruff vehicle head-on, triggering a multi-vehicle collision.
Mr. Woodruff was killed in the accident. The younger child was in a child’s car seat and was uninjured. Six-year-old Ethan was in the back seat in a booster seat secured with a seatbelt extender. The restraint released in the accident and Ethan suffered serious debilitating injuries.
Sarah Woodruff filed a product liability lawsuit against the manufacturer of the booster seat, Dorel Juvenile Group, and the manufacturer of the seatbelt extender, Ford Motor Company. The lawsuit alleged that, although both were sound products on their own, using the seatbelt extender to secure the booster seat created a dangerous condition. The lawsuit alleged that both Ford and Dorel had a duty to warn consumers not to use these products together, and they failed to give that warning.
While the Woodruff case was pending, the Tennessee Supreme Court released its opinion in another product liability lawsuit, Coffman v. Armstrong International Inc., 615 S.W.3d 888 (Tenn. 2021). The Court in Coffman held that Tennessee law did not require manufacturers of industrial equipment to warn workers of dangers from integrating asbestos products, manufactured by others, into the equipment. It dismissed Coffman’s claims.
Ford and Dorel each asked the trial court to dismiss the Woodruff claims, arguing that Coffman case barred failure-to-warn claims involving the combination of two products. The trial court dismissed the claims against Dorel, and the plaintiff appealed. The claims against Ford went to trial, but after a mistrial, the trial court allowed Ford to appeal.
In both appeals, the Court of Appeals found that the Coffman required it to dismiss the Woodruff product liability claims because neither Ford nor Dorel had a duty to warn consumers of the risks of using the seatbelt extender to secure the booster seat.
The Tennessee Supreme Court granted Sarah Woodruff permission to appeal. In the opinions released today, the Supreme Court held that Coffman did not require dismissal of the Woodruff duty-to-warn claims. The Court found that the Woodruff claims are different from those in Coffman, and the Court of Appeals erred by interpreting Coffman as broadly prohibiting all claims involving the combination of products.
To read both of the Court’s opinions in Woodruff ex rel. Woodruff et al. v. Ford Motor Company et al., authored by Justice Holly Kirby, go to the opinions section of TNCourts.gov.