Volkswagen Of America, Inc. v. Young

272 Md. 201, 321 A.2d 737 (1974)

Facts

Young (P), the decedent, was stopped at a red light. He was driving a car built by Volkswagen of America, Inc. (D). He was hit from behind by a negligent driver, and his car was pushed forward. The seat bracketing pieces and seat adjustment mechanisms broke away from the body of the car. In the 'second collision,' P was hurled into the rear of the car, injuring his head and torso. These injuries resulted in his death. P sued D, complaining that the car was 'defectively designed, manufactured, and marketed with defects which rendered it structurally hazardous, not merchantable, and not fit for the purpose intended' in that, its entire seat assembly was 'unreasonably vulnerable to separation from the floor upon collision.' After P filed his complaint, D moved to have the following question certified for decision by the Maryland Court of appeals: Whether or not the definition of the intended use of a motor vehicle includes the vehicle's involvement in a collision, and whether a cause of action is stated against the manufacturer in breach of warranty, negligence, or absolute liability that the design and manufacture of the vehicle unreasonably increased the risk of injury to occupants following a collision not caused by any defect of the vehicle.