Honda Of America Mfg., Inc. v. Norman

Facts

Karen attempted to back her car up to turn around, and she accidentally backed down a boat ramp into the water in Galveston Bay. Her passenger, Josel Woods, was not wearing a seatbelt and was able to get out of the car by crawling out the passenger side window. After escaping, Woods reached back into the sinking car to get her purse. Woods testified that Karen was calm and did not appear scared. As Woods was swimming to the ramp, she heard Karen say, 'Help me. I can't get my seatbelt undone.' Woods testified that, after she reached the ramp, she heard Karen yell to her again that she could not get out of her seatbelt. A dive team located Karen's car and all of the windows were rolled up, including the one Woods testified she had escaped through, and all the doors were closed. Karen's body was found in the back seat. An autopsy revealed Karen's blood-alcohol level was .17. The car was equipped with an automatic seat belt. The shoulder belt could be manually disengaged by pressing an emergency release button located at the juncture of the belt and the mouse. It was easy to spool out more belt to allow the occupant to lean forward and/or sideways. If the car experienced rapid deceleration (such as that encountered here when the car hit the water) or substantial tilting of the vehicle, however, the belt's emergency locking retractor would engage, preventing spooling of the belt and holding the occupant in her seat. P sued D, alleging that the seatbelt system in Karen's car was defectively designed and prevented her from getting out of the sinking car. The jury found that Karen was 25% contributorily negligent, awarded P $60 million in actual damages, and awarded $5 million to Karen's estate. The trial court reduced the award to $20 million for Karen's mother and $18 million for Karen's father, and it denied Honda's motion for remittitur as to the estate. D appealed.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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