Lawson v. Honeywell Intern'l, Inc.
| Docket Number: | 2010-CA-01924-SCT Linked Case(s): 2010-CA-01924-SCT |
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| Supreme Court: | Opinion Link Opinion Date: 10-20-2011 Opinion Author: Waller, C.J. Holding: Affirmed in part, reversed in part and remanded |
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| Additional Case Information: |
Topic: Products liability - Strict liability - Design defect - Manufacturer - Section 11-1-63 - Product designer - Negligence Judge(s) Concurring: Carlson and Dickinson, P.JJ., Randolph, Lamar, Kitchens, Chandler, Pierce and King, JJ. Procedural History: Summary Judgment Nature of the Case: CIVIL - TORTS-OTHER THAN PERSONAL INJURY & PROPERTY DAMAGE |
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| Trial Court: |
Date of Trial Judgment: 11-16-2010 Appealed from: Wayne County Circuit Court Judge: Lester F. Williamson Disposition: Granted summary judgment to Honeywell on negligence claims. Case Number: CV-2009-81-W |
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| Party Name: | Attorney Name: | Brief(s) Available: | ||
| Appellant: | Pamela Lynn Lawson |
EDWARD A. WILLIAMSON
CHRISTOPHER M. POSEY |
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| Appellee: | Honeywell International, Inc. f/k/a Allied Signal, Inc. | JOSEPH W. GILL EDWARD J. CURRIE RANDAL R. CANGELOSI | ||
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| Topic: | Products liability - Strict liability - Design defect - Manufacturer - Section 11-1-63 - Product designer - Negligence |
| Summary of the Facts: | While driving, Pamela Lawson lost control of her 1999 Jeep Cherokee. The vehicle veered off the highway and rolled over several times before coming to a stop. Lawson claims that, although she had her Gen-3 seat belt buckle correctly fastened at the time of the accident, a defective design in the buckle caused it to malfunction and disengage, resulting in her ejection from the vehicle. Lawson alleges she suffered severe injuries as a result. She filed an action against defendant Honeywell International, Inc., which she alleges originally designed the Gen-3 seat belt buckle before selling it to Chrysler in the mid-1990s. Lawson brought claims of strict liability under the Mississippi Products Liability Act, negligence, and negligence per se. Honeywell claimed, even if it did originally design the Gen-3 buckle, it still could not be held liable for Lawson’s injuries. The trial court agreed, holding that the MPLA is the exclusive remedy for products liability actions in Mississippi, and that the plain language of the MPLA does not allow design-defect claims against designers who neither manufacture nor sell the product. Lawson appeals. |
| Summary of Opinion Analysis: | Issue 1: Manufacturer The MPLA provides the exclusive remedy for strict-liability claims against a manufacturer or seller for damages caused by a product that has a design defect rendering it unreasonably dangerous. Lawson argues that the plain meaning of “manufacturer” found in section 11-1-63 shows that the Legislature intended for the MPLA to be applicable to product designers. According to Lawson, the definition of “manufacture” includes designing; thus, designers are “co-manufacturers.” However, a correct, plain-meaning analysis of the term “manufacturer” excludes a mere “designer” from falling under the statute. Since the MPLA provides no specific definition for “manufacturer,” its common or popular meaning must be applied. The common usage of the word “manufacturer”does not include “designer.” When a company merely creates the design of a product, but does not bring the product “into existence,” it is not functioning as a “manufacturer.” Thus, the trial court’s grant of summary judgment to Honeywell with respect to Lawson’s statutory claim of design defect is affirmed. Issue 2: Negligence Honeywell argues that the MPLA abrogates all common-law claims of negligence for defective products, even those asserted against nonmanufacturers. The Legislature’s intention must be determined by the total language of the statute and not from a segment considered apart from the remainder. Interpreting the MPLA as a whole reveals that claims against nonmanufacturing and nonselling designers are outside the scope of the statute. Section 11-1-63 addresses what plaintiffs must prove to hold “manufacturers” and “sellers” liable for damages caused by a product. Because the statute applies only to manufacturers and sellers, a person or entity other than the manufacturer or seller – who negligently designs a product – may be held liable for common-law negligence or under any other available theory of liability. Read plainly, the MPLA does not address what a plaintiff must prove in an action against a product designer. Holding that the MPLA is applicable to claims against designers of a product would constitute an improper addition to the statute, since designers plainly are omitted. Thus, the trial court’s grant of summary judgment to Honeywell with respect to Lawson’s common-law negligence claim is reversed. |
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