Helen M. Ramirez v. General Motors LLC

Summary

The United States District Court for the Middle District of Florida ruled on cross-motions for summary judgment in a product-liability action arising from injuries allegedly caused by side airbags in a 2021 Cadillac CT5. The court denied the plaintiff’s motion and granted General Motors LLC’s motion because the plaintiff lacked admissible expert evidence establishing a product defect or causation, and because her proposed brake-defect theory was not pleaded. The court directed entry of judgment for General Motors on both counts and closure of the case.

Holdings

1. Because the alleged defect in the Cadillac's roof-rail side airbags was not patent and involved matters beyond the capacity of laypersons, expert testimony was required to establish both product defect and causation. Plaintiff's failure to timely disclose an expert meant she could not prevail on either the strict-liability or negligence claim.
2. Plaintiff could not inject a new defective-brakes theory for the first time in a response opposing summary judgment after discovery had closed and Defendant had moved for summary judgment.
3. Plaintiff was not entitled to summary judgment, and Defendant was entitled to summary judgment on both counts because Plaintiff lacked the expert evidence necessary to prove defect and causation.

Questions Presented

1. Whether Plaintiff was entitled to summary judgment on liability for her strict-liability and negligence claims.
2. Whether Defendant was entitled to summary judgment because Plaintiff lacked expert testimony to prove that the airbags were defective and caused her injuries.
3. Whether Plaintiff could introduce a defective-brakes theory for the first time in opposition to Defendant's summary-judgment motion.
4. Whether Plaintiff's untimely expert disclosure could support her claims after the court struck the disclosure.

Disposition

other