Products Liability Law Daily Wrap Up, DESIGN AND MANUFACTURING DEFECTS—MOTOR VEHICLE EQUIPMENT—Cal. App.: Summary judgment for car seat manufacturer in GM crash that left woman paralyzed is reversed on appeal, (Nov 12, 2026)

By Molly Platnick

The court found that following GM specifications was not a defense to strict liability.

A California appellate court reversed and remanded summary judgment for a car seat manufacturer in a case brought by a woman who was paralyzed in a crash while driving a General Motors vehicle. The injured driver alleged the car seat company was strictly liable for design defect because the driver’s seat’s “open perimeter” made her injury foreseeable. The court rejected the driver’s consumer expectations theory of design defect, finding the seat’s design was too complicated for an ordinary consumer to understand without expert opinion. In its motion for summary judgment, the company argued it was not a manufacturer because it was following GM’s specifications, and raised a component part defense, which protects component sellers. The court ruled the car seat company could be found strictly liable because its role was not limited to following GM’s directive, its seats were a separate product, and it had no evidence denying that the seat caused/contributed to the driver’s injury (Gunaian v. Magna Seating of America, Inc., No. B348071 (Cal. App. Nov. 6, 2026)).

Factual background & procedural history. The driver was paralyzed when another car rear-ended her Chevrolet Equinox in October 2019. Her seat automatically reclined on impact and her spine struck her back passenger’s knees. She sued General Motors, the dealership where she purchased the car, and the other driver.

Two years later, the driver added the company that supplied and manufactured the Chevrolet’s seats, alleging the front seat was defectively designed and caused/contributed to her injury. The manufacturer moved for summary judgment, claiming the seat did not cause the driver’s injury and, even if it had, it was built to GM’s specifications.

Expert testimony. The driver’s automotive expert opined that “injury risks are entirely foreseeable” because the seat’s “open perimeter frame” is covered only by “thin fabric which is insufficient to prevent” a driver from hitting a rear passenger’s legs when the seat reclines. An engineering expert added the open perimeter frame “placed a concentrated load on her back and spine, which hyperextended and resulted in paralysis.”

The seat manufacturer’s collision engineer inspected the allegedly defective seat and “found no deformity or failure,” concluding the benefit of its foam design outweighed any risks. The company’s chief engineer and a GM technical expert separately testified that GM specified the car seat’s “material specifications and performance requirements” and that the supplier had “no authority to modify or deviate from its design.” However, GM did not “dictate” how the company manufactured the seat foam.

The trial court granted the manufacturer’s motion for summary judgment, finding the driver did not sufficiently identify any defects in the car seat and that GM was responsible for the design.

Manufacturer not liable for design defect. The driver argued the car seat was defectively designed based on the consumer expectation test. The test applies if the product (a) does not have a common safety device or (b) seriously fails or malfunctions. The court emphasized the test looks to the ordinary consumer’s “everyday experience” and should not be based on “expert opinions about the merits.” The consumer expectation test did not apply here because the injured driver’s claim was based on “complex and technical issues.” The average consumer would not “intuitively” understand the “open perimeter” design and would need to rely on expert testimony to determine if it was unsafe.

Strict liability claim remanded. The car seat company contended it was a supplier, but not a manufacturer, because it was merely following GM’s specifications. The court declined to split hairs, stating “it did, in fact, manufacture the seat by taking various components…and fashioning them into a completed seat.” Quoting the GM expert’s testimony referenced above, the court was satisfied the car seat company might “be directly responsible” for there only being “thin fabric” protecting the seat. Even if the car seat manufacturer had only followed GM’s specifications, it would not be shielded from liability because California courts have consistently adhered to an “enterprise stream of commerce liability.” This rule holds that “if one is part of the overall production and marketing enterprise, he may not escape liability by arguing he had no control over the cause of the defect.”

Component part defense not applicable. The car seat company argued it was protected as a component seller. A supplier can evade liability as a component seller only if (1) it provided a component or material that was not itself defective; (2) the component or material is changed or transformed when incorporated through the manufacturing process into a different finished product; and (3) the end user is allegedly injured by a defect in the finished product. The court based its analysis on Romine v. Johnson Controls (2014), which held the component part defense did not apply to a car seat because “it was a separate product with a specific purpose and use.” The court determined none of the three prongs was true in this case: (1) the driver said the car seat itself was defective; (2) the seat was not changed or transformed when it was installed into the Chevrolet; and (3) the driver was injured because the seat caused her to hit her back on the rear passenger’s legs.

Once the court rejected the car seat company’s theory that it was not liable as a manufacturer, the company had no admissible evidence its design did not cause/contribute to the driver’s injury. Its experts opined on whether the subject car seat deviated from specifications, but neither addressed “technical issues within the manufacturer’s knowledge.” The company’s suggestion that the other driver caused the injury did not persuade the court, which elucidated that a “manufacturer may be liable for injuries sustained in a car accident where a defect, though not the cause of the accident, causes or contributes to the plaintiff’s injuries.”

The case is No. B348071.

Judge: Lui, E.

Attorneys: Armen Akaragian (Mardirossian Akaragian, LLP) for Susan Gunaian and Ararat Issayan. Douglas W. Robinson (Palmieri Tyler Wiener Wilhelm Waldron, LLP) for Magna Seating of America, Inc. and Magna Seating, Inc. Dommond E. Lonnie (Dykema Gossett, LLP) for General Motors LLC and Allen Gwynn Chevrolet, Inc. Barry R. Schirm (Hawkins, Parnell & Young, LLP) for Lear Corp. Stephen C. Pasarow (Knapp Petersen & Clarke) for Alma B. Hernandez-Sanchez.

Companies: Magna Seating of America, Inc.; Magna Seating, Inc.; General Motors LLC; Allen Gwynn Chevrolet, Inc.; Lear Corp.

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