Bonds v. Hyundai Motor Co.

          MEMORANDUM OPINION

          KARON OWEN BOWDRE CHIEF UNITED STATES DISTRICT JUDGE.

         This wrongful death and products liability case comes before the court on Plaintiff Willie Earl Bonds's “Motion for Summary Judgment on Defendants' Affirmative Defenses of Contributory Negligence and Assumption of the Risk.” (Doc. 90).

         Marvin Culver, the backseat passenger of a 1997 Hyundai Accent, was partially ejected from the vehicle when his door opened during a collision. Mr. Culver suffered catastrophic injuries from the wreck and died nearly a year later.

         Mr. Bonds, the administrator of Mr. Culver's estate, brings wrongful death and products liability claims for Mr. Culver's death against Defendants Hyundai Motor Company and Hyundai Motor America under the Alabama Extended Manufacturer's Liability Doctrine, Ala. Code § 6-5-500, et seq. Mr. Bonds alleges that the Accent's door opened during the collision because of a defective door locking and latching system.

         Hyundai raises the affirmative defenses of contributory negligence and assumption of the risk based on Mr. Culver's failure to wear a seatbelt and failure to exercise reasonable care in handling the door locking and latching system.

         Mr. Bonds moved for summary judgment on Hyundai's affirmative defenses, which the court will GRANT IN PART and DENY IN PART. Because front seat passengers are not contributorily negligent for not wearing a seatbelt by statute, Hyundai cannot rely on Mr. Culver's failure to wear a seatbelt as evidence of contributory negligence even though he was a back seat passenger. But because evidence exists of the visibly damaged condition of Mr. Culver's door handle and the latch system, a jury must decide whether Mr. Culver assumed the risk of being ejected from the car by not wearing his seatbelt and whether he was contributorily negligent or assumed the risk of his door opening in a collision by not locking his door.

         I. STANDARD OF REVIEW

         A trial court can resolve a defendant's affirmative defenses on summary judgment only when the plaintiff establishes two essential elements: (1) no genuine disputes of material fact exist; and (2) the plaintiff is entitled to judgment as a matter of law as to the affirmative defense. See Fed. R. Civ. P. 56(a); see also Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986) (finding that the Rule 56 standard applies to motions for summary judgment on any dispositive issue for which the nonmoving party will bear the burden of proof at trial).

         Under the first element of the moving party's summary judgment burden, “‘[g]enuine disputes [of material fact] are those in which the evidence is such that a reasonable jury could return a verdict for the non-movant.'” Evans v. Books-A-Million, 762 F.3d 1288, 1294 (11th Cir. 2014) (emphasis added) (quoting Mize v. Jefferson City Bd. of Educ., 93 F.3d 739, 742 (11th Cir. 1996)). A court will consider an issue of fact “material” if “it is a legal element of the claim under the applicable substantive law which might affect the outcome of the case.” Allen v. Tyson Foods, Inc., 121 F.3d 642, 646 (11th Cir. 1997) (citing Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986)). And a court will consider an issue of fact “genuine” if “the record taken as a whole could lead a rational trier of fact to find for the nonmoving party.” Id.

         The court must view the record evidence in the light most favorable to the non-moving party and draw reasonable inferences in favor of the non-moving party. White v. Beltram Edge Tool Supply, Inc., 789 F.3d 1188, 1191 (11th Cir. 2015). And reasonable inferences drawn from record evidence can defeat a motion for summary judgment because “‘the drawing of legitimate inferences from the facts are jury functions, not those of a judge.'” Carlson v. FedEx Ground Package Sys., Inc., 787 F.3d 1313, 1318 (11th Cir. 2015) (quoting Allen, 121 F.3d at 646).

         II. BACKGROUND

         On May 18, 2011, Dareyan Byrd, the driver of the Hyundai Accent, and Casey Cauley, the front passenger, offered Mr. Culver a ride. Mr. Culver opened the rear driver's side door of the Accent, sat in the backseat behind the driver's seat, and closed the door.

         According to Mr. Byrd and Ms. Cauley, Mr. Culver completely shut his door, no lights or sounds from the Accent indicated that he did not, and Mr. Culver did not mention that he had any trouble with the door. (Doc. 91-1 at 21; Doc. 91-2 at 8). But, according to Mr. Byrd, the interior handle on the rear driver's side door was broken and hung loosely from its position on the door. (Doc. 91-1 at 10, 13- 14, 16, 36, 54, 56). The broken handle exposed a metal rod inside the door that a person would have to pull to open the door from the inside. (Id. at 12-13, 15-16, 36).

         Soon after they drove away, the Accent collided with a United States Postal truck. Mr. Culver was not wearing his seatbelt at the time of the collision. Mr. Culver's door opened during the collision, he was partially ejected from the car, and his head struck the ground. He suffered severe injuries from the accident that rendered him quadriplegic. ...