Dawson v. Chrysler Corp.
630 F.2d 950 (3d Cir. 1980)

Facts:

  • As Dawson (police officer) was driving on a rain-soaked highway, responding to a burglar alarm, he lost control of his patrol car (1974 Dodge Monaco) and struck a steel pole.
  • The vehicle literally wrapped itself around the pole and the pole ripped through the body of the car and crushed Dawson between the seat and the “header” area of the roof.
    • Dawson was rendered a quadriplegic.
  • Plaintiffs’ experts testified that the patrol car was defective because it did not have a full, continuous steel frame extending through the door panels, and a cross-member running through the floor board between the posts located between the front and rear doors of the vehicle.
    • Had the vehicle been so designed, the Dawsons alleged, it would have “bounced” off the pole following relatively slight penetration by the pole into the passenger space.
  • D argued that this change would add 250 lbs. and $300 to the car, and arguably wouldn’t be any safer.

History:
The jury awarded Mr. Dawson $2,064,863.19 for his expenses, disability, and pain and suffering, and granted Mrs. Dawson $60,000.00 for loss of consortium and loss of services.

Issue:
Whether sufficient evidence was presented from which the jury reasonably might infer that the alternative design proffered would be safer than the existing design, or that it would be cost effective, practical, or marketable.

Holding:
Yes. Affirmed.

Reasoning:

  • Their experts noted that with the alternative design the pole would have penetrated only 9.9 inches into the passenger space, and thus would not have crushed Dawson.
    • Under these circumstances, according to the biochemical engineer, Dawson would have been able to “walk away from the accident” with but a bruised shoulder.
  • Additionally, the U.S. Dept. of Transportation noted that the frame improvements similar to those proposed by the experts presented by the Dawsons reduced intrusion into the passenger area by fifty percent, from sixteen inches to eight inches.
  • Thus, the record was sufficient to sustain the jury’s findings.
  • The court did caution, however, that these cases have broad implications that Congress should probably address – i.e., permitting individual juries applying varying laws in different jurisdictions to set nationwide automobile safety standards imposes on automobile manufacturers conflicting requirements.
  • It would be difficult for members of the industry to alter their design and production behavior in response to jury verdicts in such cases, because their response might well be at variance with what some other jury decides is a defective design.
  • Note: It is fair to say that today all states still recognize crashworthiness liability.