Benson v. Honda Motor Co

In Benson v. Honda Motor Co. (1994) 26 Cal.App.4th 1337, the witness was a product analysis engineer who had been employed by Honda for 22 years. He testified that his job duties included the review of products liability claims. He further testified that Honda's legal department collected "all customer complaints, claims or lawsuits concerning personal injuries as part of its regular course of business. Honda kept a permanent, computerized system to record such complaints made since at least 1970. Honda's safety records department also collected information from police reports and product inspections. Among the information regularly recorded in its computer system is identification of the vehicles involved, accident descriptions and injuries to the occupants of the vehicles. A narrative section in these records describes accidents in some detail. ... Furthermore, the computer system could generate specific information regarding products and accidents involving particular model years." (Id. at p. 1347.) The appellate court found Honda's foundational showing sufficient. (Id. at pp. 1347-1348.)