Kia Motors Corp. v. Ruiz

Summary

The Texas Supreme Court considered a products-liability action arising from the failure of a driver's-side frontal air bag to deploy during a collision. The Court held that Texas Civil Practice and Remedies Code section 82.008's rebuttable presumption of nonliability did not apply because FMVSS 208 did not govern the risk of air-bag deployment failure, and that the evidence was legally sufficient to support the negligent-design finding. However, the Court held that the trial court improperly admitted a spreadsheet of warranty claims, that Kia preserved the error, and that the error was harmful, requiring a new trial.

Holdings

1. Compliance with FMVSS 208 did not trigger section 82.008's rebuttable presumption because FMVSS 208 did not govern the product risk alleged to have caused the injury: failure of the driver's-side air bag to reliably activate and deploy.
2. Section 82.008 does not require a federal regulation to mandate a particular product design; a manufacturer's chosen design may comply with a performance-based safety standard. That interpretation does not, however, make FMVSS 208 applicable here because the standard did not govern the relevant deployment-failure risk.
3. The Ruiz family presented legally sufficient evidence to support the jury's negligent-design finding.
4. The trial court erred in admitting the spreadsheet because substantial portions were irrelevant, and Kia preserved its objection without requesting a limiting instruction.
5. Admission of the spreadsheet was harmful because it probably resulted in an improper judgment.

Questions Presented

1. Whether Texas Civil Practice and Remedies Code section 82.008 created a rebuttable presumption of nonliability based on the Spectra's compliance with Federal Motor Vehicle Safety Standard 208.
2. Whether the evidence was legally sufficient to support the jury's negligent-design finding.
3. Whether the trial court erred by admitting the spreadsheet of warranty claims involving air-bag circuitry.
4. Whether Kia preserved its objection to the spreadsheet and whether its admission was harmful.

Disposition

reversed_and_remanded