Earlier this month, a state appellate court issued a written opinion in a product liability case brought by the owner of a Mazda Miata against the car’s manufacturer. In the case, Holiday Motor Corporation v. Walters, the plaintiff alleged that the manufacturer breached an implied warranty of merchantability by not creating a soft-top convertible that was capable of withstanding a rollover crash. Ultimately, the court rejected the plaintiff’s claims and imposed judgment for the defendant car manufacturer, based on the fact that the manufacturer did not have a duty to create a soft-top convertible capable of withstanding a rollover crash.
Walters was driver her 1995 Mazda Miata on a two-lane road when she noticed a large object fall off the truck in front of her. In an attempt to avoid the object, Walters steered the car to the left, across the oncoming lane of traffic, and off the side of the road. As the car left the roadway, it traveled up a slight incline that caused the vehicle to roll over. Eventually, the car came to a stop with the car upside down leaning partially against a tree.
A good Samaritan stopped to render assistance to Walter, who was trapped inside. He testified at trial that when he arrived on the scene, the car was lying flat on the ground upside down. Only the rear of the car was slightly elevated. Walters sustained serious back and neck injuries as a result of the accident, and she filed a product liability case against Mazda. She argued that the soft-top convertible should have been able to maintain its integrity during the accident.