Pruitt v. General Motors Corp

In Pruitt v. General Motors Corp. (1999) 72 Cal.App.4th 1480, the plaintiff sued an automobile manufacturer for injuries sustained after the air bag deployed in a frontal collision with an oncoming car. The trial court refused to instruct the jury under the consumer expectation test. Division Six of our court affirmed, holding "the deployment of an air bag is, quite fortunately, not part of the 'everyday experience' of the consuming public. Minimum safety standards for air bags are not within the common knowledge of lay jurors . . . who are in need of expert testimony to evaluate the risks and benefits of the challenged design." (Ibid.) The court found no error in the trial court's refusal to instruct the jury in an automotive airbag injury case on the consumer expectations test. Instead, the trial court instructed the jury on theories of risk benefit and failure to warn. The Court of Appeal stated: "The deployment of an air bag is, quite fortunately, not part of the 'everyday experience' of the consuming public. Minimum safety standards for air bags are not within the common knowledge of lay jurors. Jurors are in need of expert testimony to evaluate the risks and benefits of the challenged design. Even [the plaintiff's] own expert testified that in designing air bags there are tradeoffs involving complex technical issues." ( Id. at pp. 1483-1484.)