An Illinois Supreme Court ruling in a product liability lawsuit confirms that manufacturers are not required to guard against every risk to the consumer. The verdict in Dora Mae Jablonski v. Ford Motor Company, No. 110096, reversed a $43 million judgment in a 5-0 vote.
Jablonski was filed as a result of a rear-end car accident involving Dora Mae and John Jablonski. The couple was traveling in their 1993 Lincoln Town Car when they were struck by a Chevrolet Lumina that was traveling at 60 mph. The impact of the collision was such that it propelled a pipe wrench laying in the truck of the Jablonski’s vehicle through the trunk walls and into the nearby fuel tank. The punctured fuel tank caused the car to catch fire, leaving John Jablonski dead and Dora Mae severely burned.
Dora Mae and her son brought a product liability lawsuit against Ford Motor Company, alleging that it had negligently designed a defective and dangerous fuel tank system in its Lincoln Town Car. According to the plaintiffs’ theory of liability, the design of the Town Car’s rear fuel tank system left it susceptible to puncture or being damaged during a rear-end collision.
The plaintiffs received a $43 million award for what the trial court ruled was the auto manufacturer’s negligence. Ford then appealed the product liability decision at the Illinois Appellate Court level, but was unable to get the large verdict reversed. The Illinois Appellate Court affirmed the trial court’s decision, at which point Ford elected to bring its appeal to the Illinois Supreme Court.
The basis of Ford’s appeal was that the plaintiffs had failed to demonstrate that the auto manufacturer had breached any of the standards of care recognized in Illinois. Fortunately for Ford, the Illinois Supreme Court agreed. In its ruling on the product liability lawsuit, the supreme court established that in the case of a negligence product design lawsuit, the general rule in determining negligence is a risk-utility balancing test. And while “compliance with industry standards is a relevant factor in that analysis…it is not dispositive.”
When the supreme court applied this risk-utility balancing test, it determined that the plaintiffs had failed to present sufficient evidence to prove that Ford had breached a duty of reasonable care to its consumers. As such, a jury should not have been able to find the car manufacturer guilty based on the trial evidence.
And while it is possible that the plaintiffs might have established that Ford had breached its postsale duty to warn consumers of the Town Car’s design defect, this duty is not recognized under Illinois law and is therefore not applicable. As a result, the supreme court held that the voluntary undertaking of the postsale duty to warn state employees did not create a subsequent duty to warn civilian consumers.
Given its analysis, the supreme court could not find sufficient evidence to uphold the lower courts’ rulings and therefore reversed the $43 million verdict entered in Jablonski. Because Ford complied with the current government and industry design standards at the time the Lincoln Town Car was manufactured, it therefore demonstrated that it had balanced the foreseeable risks with its design’s utility. This decision releases car manufacturers from the seemingly impossible duty of guarding against every conceivable risk regardless of harm.
Kreisman Law Offices has been handling Illinois product defect lawsuits for individuals and families for more than 35 years in and around Chicago, Cook County, and surrounding areas, including Des Plaines, Oak Lawn, Melrose Park, and Rolling Meadows.
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