Car Manufacturer Victorious on Appeal of Alleged Breach of Implied Warranty of Merchantability

Earlier this month, an appellate court in Virginia issued a written opinion in a product liability case that ended up reversing a jury’s verdict in favor of the plaintiff. In the case, Holiday Motor Corp. v. Walters, the court set aside the jury’s verdict because the car manufacturer did not have a duty to customers to manufacture a soft-top convertible that could safely withstand a rollover crash.

ConvertibleThe Facts of the Case

Walters was the owner of a 1995 Mazda Miata soft-top convertible. Back in 2006, Walters was driving the Miata on a two-lane road with the soft-top in the closed position when she saw a large object fall off the back of a pick-up truck. To avoid colliding with the large object, she veered to the left across the opposite lane of traffic and up a grassy embankment on the side of the road. As the vehicle left the road, it rolled over and ended up leaning against a tree.

A passerby stopped to offer assistance. He testified at trial that the windshield was flat against the ground, but the rear end of the car was slightly elevated. Walters ended up suffering a serious cervical spine injury and sued Mazda based on a product liability theory. Specifically, Walter argued that Mazda violated the implied warranty of merchantability in that the design of the vehicle’s soft-top was unreasonably dangerous in failing to protect against rollover crashes.

Walters was successful at trial, but Mazda appealed. On appeal, Mazda argued two main theories, only one of which is relevant to this discussion. Mazda argued that it did not have a duty to manufacture a soft-top convertible that could safely withstand a rollover crash. Mazda argued that consumers do not generally expect that a soft-top convertible will provide protection in a rollover crash, and other vehicle manufacturers do not make models that provide such protection. In other words, Mazda argued that the industry standard was not to manufacture soft-top convertibles that could withstand rollover collisions.

The court agreed with Mazda, noting that there were no national standards in place at the time of the car’s manufacture requiring safety standards for soft-top convertibles. Similarly, the court added, the fact that a car is a soft-top convertible is a very unique function of the vehicle and likely one of which the consumer is aware. The court explained that this is a feature that is so unique that it is likely that the owner specifically sought it out. Thus, the consumer should be aware that a soft-top convertible will not provide the same sort of protection as a regular model vehicle.

Have You Been Injured in a Maryland Car Accident?

If you or a loved one has recently been involved in a single-vehicle car accident in the Maryland, Virginia, or Washington, D.C. area, you may be entitled to monetary compensation. Even though no other vehicles were involved in your accident, there is the possibility that your vehicle was not designed properly to withstand a collision or was otherwise defectively designed or manufactured. To discuss your case with an experienced personal injury attorney and to learn more about the various types of product liability lawsuits, call 410-654-3600 to set up a free consultation today.

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