Judge: Melvin D. Sandvig, Case: 21STCV02112, Date: 2024-10-29 Tentative Ruling

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Case Number: 21STCV02112    Hearing Date: October 29, 2024    Dept: F47

Dept. F47

Date: 10/28/24                                                                 TRIAL DATE: 3/24/25

Case #21STCV02112

 

SUMMARY JUDGMENT/SUMMARY ADJUDICATION

 

Motion filed on 6/17/24.

 

MOVING PARTY: Defendant Lear Corporation

RESPONDING PARTY: Plaintiffs Susan Gunaian and Ararat Issayan

NOTICE: ok

 

RELIEF REQUESTED: An order granting summary judgment in favor of Defendant Lear Corporation (Lear) and against Plaintiffs Susan Gunaian and Ararat Issayan.  Alternatively, Lear moves for summary adjudication of the following issues:

 

Issue 1: Plaintiffs cannot establish a defect in design/manufacture existed and/or caused the subject collision and/or Plaintiffs’ claimed damages to occur.

 

Issue 2: Plaintiffs cannot establish negligence on the part of Lear that caused the subject collision and/or Plaintiffs’ claimed damages to occur. 

 

Issue 3: Plaintiffs cannot establish a failure to warn on the part of Lear that caused the subject collision and/or Plaintiffs’ claimed damages to occur. 

 

RULING: The request for summary judgment is granted.

 

SUMMARY OF FACTS & PROCEDURAL HISTORY

 

This action arises out of a motor vehicle accident that occurred on 10/11/19 when the 2018 Chevrolet Equinox driven by Plaintiff Susan Gunaian (Gunaian) was rear-ended by a vehicle driven by Defendant Alma Hernandez-Sanchez on the I-5 Freeway in Los Angeles, California.  (Complaint ¶¶3, 10, 20; Separate Statement (SS) 2).  Plaintiff Aarat Issayan (Issayan) is Gunaian’s spouse and asserts a claim for loss of consortium.  (Complaint ¶14).  Plaintiffs allege that Gunaian suffered catastrophic and permanently disabling injuries as  a result of the accident.  (Id. at ¶12). 

 

On 1/19/21, Plaintiffs filed this action against General Motors LLC (General Motors); Allen Gwynn Chevrolet, Inc.; Hernandez-Sanchez and Does 1-100 for: (1) Strict Products Liability and (2) Negligence.  On 8/29/22, Plaintiffs filed an Amendment to Complaint naming Lear Corporation (Lear) in place of Doe 1.  Plaintiffs’ claims are based on design defect, manufacturing defect and failure to warn.  (SS 3).   

 

On 6/17/24, Lear filed the instant motion seeking an order granting summary judgment in favor of Lear and against Gunaian and Issayan (collectively, Plaintiffs).  Alternatively, Lear moves for summary adjudication of the following issues:

 

Issue 1: Plaintiffs cannot establish a defect in design/manufacture existed and/or caused the subject collision and/or Plaintiffs’ claimed damages to occur.

 

Issue 2: Plaintiffs cannot establish negligence on the part of Lear that caused the subject collision and/or Plaintiffs’ claimed damages to occur. 

 

Issue 3: Plaintiffs cannot establish a failure to warn on the part of Lear that caused the subject collision and/or Plaintiffs’ claimed damages to occur. 

 

Plaintiffs have not opposed or otherwise responded to the motion. 

 

ANALYSIS

 

A defendant may move for summary judgment/summary adjudication if it is contended that the cause of action has not merit.  See CCP 437c(a)(1); CCP 437c(f)(1).  A defendant has met its burden of showing that a cause of action has no merit if the party has shown that one or more elements of the cause of action cannot be established, or that there is a complete defense to the cause of action.  See CCP 437c(o), (p)(2).  Once the defendant has met its initial burden, the burden shift to the plaintiff to show that a triable issue of material fact exists as to the cause of action or a defense thereto.  CCP 437c(p)(2). 

 

1st cause of action – Strict Products Liability

 

Strict products liability may be imposed for: (1) manufacturing defects, (2) design defects and (3) warning defects.  See Daly (1978) 20 C3d 725, 733 citing Anderson (1991) 53 C3d 987, 995.  In order to be held liable under a strict products liability theory, the plaintiff’s injury must have been caused by a defect in the defendant’s product.  Daly, supra; See also Taylor (2009) 171 CA4th 564, 576-577; Sindell (1980) 26 C3d 588, 597-598.

 

A manufacturer’s liability is limited to the risks created by an actual defect in its own product.  O’Neil (2012) 54 C4th 335, 347-348.  A manufacturer of a component part is not liable when another manufacturer’s product used in conjunction with its product is the alleged cause of injury.  Id. at 362.

 

Plaintiffs’ discovery responses establish that they are claiming the Equinox had  defects in: (1)  the occupant restraint system and (2) the seat occupied by Gunaian.  (SS 5-8).  Plaintiffs further contend that Lear supplied the purportedly defective occupant restraint system and the seat.  (SS 11-12).  However, the unrefuted evidence establishes that Lear had no involvement with the occupant restraint system (seat belt and air bag systems) or the driver’s seat itself.  The Equinox was made by General Motors and the seat was made by a defendant other than Lear.  Lear only manufactured tracks for the front seats of the Equinox pursuant to General Motors’ design and specifications.  (SS 13-16).

 

A product has a manufacturing defect if it differs from the manufacturer’s intended result or from other identical units of the same product line – i.e., a product is defective if it does not conform to the manufacture’s design.  See Garrett (2013) 214 CA4th 173, 190.

 

Plaintiffs have not alleged any defect in the design or manufacture of the seat tracks and there is no evidence of any such defects.  The design and specifications for the seat tracks were provided to Lear by General Motors and Lear was obligated to manufacture the tracks according to General Motors’ design and specifications.  As the completed product manufacturer, General Motors, not Lear, incorporated the seat tracks into the Equinox.  (SS 15-16).  Further, an inspection of the Equinox after the accident confirmed that the seat tracks conformed to the General Motors’ design and did not have any defect.  (SS 17).

 

A manufacturer does not have a duty to warn of hazards arising solely from other manufacturer’s products.  O’Neil, supra at 351.  Here, there is no evidence of any hazard inherent in the seat tracks which caused Gunaian’s injury and/or required a warning.

 

The evidence further shows that after the accident the seat tracks were fully secured to the floor of the vehicle and in their intended positions such that there was no failure of the seat tracks.  (SS 14).  As such, there is no evidence that the seat tracks caused or contributed to Gunaian’s injury.

 

2nd cause of action – Negligence

 

Plaintiffs’ negligence cause of action incorporates all of the prior allegations.  (SS 4).  As noted above, Plaintiffs do not allege the seat tracks were defective and the evidence does not support such a finding.  (SS 11-12, 14-17).  There is also no evidence that the seat tracks caused Gunaian’s injury.  (SS 14).  The negligence claim fails for the same reasons the strict liability claim fails.  See Lambert (1998) 67 CA4th 1179, 1185.

 

CONCLUSION

 

The request for summary judgment is granted.