General Motors Corporation and Lawrence Marshall Chevrolet Oldsmobile, Inc. v. A.J. Sanchez, et al.

Summary

The Supreme Court of Texas addresses when comparative responsibility applies in a strict-products-liability case. It holds that a consumer has no duty to discover or guard against a product defect, but conduct beyond that mere failure may be compared under Texas's comparative responsibility statute. The court also concludes that the evidence was legally insufficient to support punitive damages and reverses and renders judgment reducing actual damages by the jury's comparative responsibility finding.

Holdings

1. The plaintiffs presented more than a scintilla of evidence that the proposed alternative design was technically and economically feasible and would substantially reduce the risk of injury; therefore, the design-defect finding was supported by legally sufficient evidence.
2. Comparative responsibility applies in a strict-liability products case when the consumer's negligence is something other than the mere failure to discover or guard against a product defect.
3. Keen is disapproved to the extent it suggests that all consumer conduct other than assumption of a known risk is merely a failure to discover or guard against a product defect and therefore cannot be compared.
4. The evidence was legally insufficient to establish General Motors's conscious indifference, an essential element of gross negligence; punitive damages therefore could not be awarded.

Questions Presented

1. Whether the evidence was legally sufficient to support the finding that the truck had a design defect, including proof of a safer alternative design.
2. Whether comparative responsibility applies in a strict-liability products case when the consumer's conduct is negligence beyond the mere failure to discover or guard against a product defect.
3. Whether legally sufficient evidence supported the finding that General Motors was grossly negligent and therefore liable for punitive damages.

Disposition

reversed