Products Liability Law Daily Wrap Up, DESIGN AND MANUFACTURING DEFECTS—MOTOR VEHICLE EQUIPMENT—N.D. Ill.: General Motors wins summary judgment in fatal truck crash case, (Oct 14, 2026)

By Pankhuri Bhatnagar, B.A. LL.B.

The court declined to reconsider its earlier rulings excluding the estate’s expert opinions, and the lack of expert testimony warranted judgment for the automaker.

In an action brought against an automaker by the surviving spouse of a woman who died in a crash after losing control of her car due to its alleged design defects, a federal district court in Illinois granted summary judgment to the manufacturer. The court observed that the estate’s strict liability and negligence claims required proof of a product defect and causation; that expert opinions concerning the alleged defect, accident causation, and the driver’s reactions remained excluded; that complex mechanical issues and the medical cause of death required expert testimony; and that the claims failed without such evidence (Hanafin v. General Motors, LLC, No. 22 CV 1408 (N.D. Ill. Oct. 1, 2026)).

Background. In May 2021, the woman was driving a 2018 GMC Sierra 1500 pickup truck manufactured by General Motors LLC when it crossed the center line, travelled at least 36 feet through the air, and landed in a ditch. She suffered spinal fractures and underwent surgery but ultimately passed away due to a pulmonary embolism caused by deep vein thrombosis. The coroner identified heart disease and obesity as contributing factors. Her surviving spouse, acting individually and as administrator of her estate, alleged that a malfunctioning ball joint and control arm assembly altered the truck’s steering response, causing the crash. The court excluded the opinions of the estate’s experts. General Motors sought summary judgment, arguing that the remaining evidence could not establish defect or causation. The estate sought reconsideration of the expert rulings and alternatively argued that the claims could proceed without expert testimony. It also contended that the ball joint had a 10-year life expectancy, failed prematurely, and may have separated before the truck left the roadway.

Engineering expert. The man claimed that his engineer’s opinions concerning an alleged ball joint defect and crash causation were reliable and that the court erred in relying on Burns v. Sherwin-Williams Co., 78 F.4th 364 (7th Cir. 2023) to exclude those opinions. In Burns, expert evidence was excluded for lack of testing, peer review, and general industry acceptance. Likewise, the engineer here conducted no controlled experiments, simulations, or complete accident reconstruction and relied on personal experience without explaining a verifiable methodology. Under Timm v. Goodyear Dunlop Tires North America, Ltd., 932 F.3d 986 (7th Cir. 2019), physical examination alone could not substitute for empirical data or testing validating the conclusions. The court distinguished Schmude v. Tricam Industries, Inc., 550 F. Supp. 2d 846 (E.D. Wis. 2008), which involved a comparatively simple ladder defect, because the truck’s steering assembly required technical knowledge beyond a lay jury’s understanding. Accordingly, there was no basis to reconsider either exclusion.

Medical expert. The estate argued that its medical expert had performed a differential diagnosis and needed only to identify a contributing cause of the driver’s injuries. The court found no evidentiary support for the asserted methodology. The expert had expressly disavowed using a differential diagnosis and did not explain which alternative causes he considered. The estate’s reliance on Schultz v. Akzo Nobel Paints, LLC, 721 F.3d 426 (7th Cir. 2013) was unhelpful as the expert there had used a differential diagnosis to assess competing causes. The court upheld its reliance on Robinson v. Davol Inc., 913 F.3d 690 (7th Cir. 2019), which rejected general assurances of reliable methods without an explained methodology, and the medical opinion remained excluded.

Metallurgy expert. The estate maintained that its metallurgist used a process of elimination to determine when and why the ball joint separated. The court found that the estate merely repeated arguments rejected in its earlier ruling and offered no report or deposition citations supporting the asserted methodology. Under Beamon v. Marshall & Ilsley Trust Co., 411 F.3d 854, 862 (7th Cir. 2005), unsupported arguments are waived.

Human-factors expert. The spouse submitted that his human-factors expert had sufficient familiarity to opine on the driver’s reactions during the crash. The court had found his training insufficiently detailed and his methodology unexplained. The estate’s cursory assertion did not remedy those deficiencies. Thus, all four expert opinions remained excluded.

Defect and causation. Under Illinois law, both strict liability and negligence require proof of an unreasonably dangerous defect and proximate causation. Expert testimony is not invariably necessary for a product defect, but it is required when the design and operation exceed ordinary experience. In Tweedy v. Wright Ford Sales, Inc., 64 Ill. 2d 570 (1976), a jury could infer a defect when a brake pedal suddenly sank to the floor without slowing the vehicle. By contrast, Show v. Ford Motor Co., 659 F.3d 584 (7th Cir. 2011), required expert testimony to explain a vehicle rollover involving complex design and accident mechanics. The court found the truck’s control arm and ball joint assembly similarly technical: jurors needed expert evidence to understand how the joint connected to the control arm, affected steering, and allegedly separated because of a design flaw. Expert testimony was also necessary to connect the crash and subsequent medical care to the pulmonary embolism, particularly given the driver’s other risk factors for blood clots.

The remaining evidence did not create a triable issue. The estate’s assertions about the ball joint’s expected lifespan, noises during the crash, and the timing of its separation relied primarily on excluded expert material. The only admissible disputed evidence concerned the post-crash condition of the vehicle and ball joint. That evidence did not establish that the design was defective or unreasonably dangerous. Because liability could not rest on speculation or a merely possible causal connection, the court granted summary judgment to General Motors on all claims.

The case is No. 1:22-1408.

Judge: Harjani, S.

Attorneys: Thomas G. Siracusa (Power Rogers, LLP) for Charles Hanafin. Justin B. Weiner (Bush Seyferth PLLC) for General Motors, LLC.

Companies: General Motors, LLC

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