## Facts

- Richard F. Dawson, a Pennsauken, New Jersey police officer, was driving a 1974 Dodge Monaco patrol car while responding to a burglar alarm on a rain-soaked highway.
- Dawson lost control; the car slid off the road and struck an unyielding steel pole (about 15 inches in diameter).
- The vehicle hit the pole backward at roughly a 45-degree angle on the left side, with impact at the left rear wheel well; the body wrapped around the pole.
- The pole intruded into the passenger compartment and crushed Dawson between the seat and the roof header area above the windshield.
- Dawson suffered severe cervical injuries and became quadriplegic.
- Dawson and his family sued Chrysler Corporation in strict products liability, alleging a design defect: inadequate structural/frame protection in foreseeable collisions and the feasibility of stronger reinforcement at reasonable cost.

## Issues

1. Whether, under New Jersey law, an automobile manufacturer owes a duty to design a reasonably crashworthy vehicle for foreseeable collisions.
2. Whether sufficient evidence supported the jury’s finding that the vehicle’s design was defective under New Jersey’s risk–utility analysis.
3. Whether sufficient evidence supported proximate cause—that the alleged design defect was a substantial factor in producing Dawson’s enhanced injuries.
4. Whether asserted evidentiary errors required a new trial.
5. Whether the district court erred in awarding and calculating prejudgment interest.

## Decision

- The Third Circuit affirmed the district court’s judgment for the plaintiffs.
- The court held that New Jersey law recognizes a manufacturer’s duty to design vehicles that are reasonably safe for intended and foreseeable use, including foreseeable crashes.
- The court concluded the record contained sufficient evidence for the jury to find a design defect and to find the defect was a substantial factor in Dawson’s injuries.
- The court rejected Chrysler’s argument that compliance with federal motor-vehicle safety standards immunized it from state design-defect liability; compliance was relevant but not conclusive.
- The court found no reversible evidentiary error and upheld the prejudgment interest award and calculation under New Jersey practice.

## Legal Principles

- In New Jersey strict products liability, once duty is established, the jury decides whether the product was defective and whether the defect proximately caused the injury.
- Crashworthiness is part of a manufacturer’s obligation to make a product reasonably safe for foreseeable use; a vehicle may be defective for failing to provide reasonable occupant protection in foreseeable collisions.
- New Jersey design-defect claims apply a risk–utility balancing inquiry, weighing the magnitude of danger against the benefits of the design as marketed, including the feasibility and cost of safer alternative designs.
- Compliance with federal safety standards is admissible and may be considered by the factfinder, but it does not bar a state-law design-defect claim absent clear federal displacement.
- Proximate cause may be shown where the design defect increases the severity of injury in a crash (enhanced-injury concept), and the jury may attribute the additional harm to the defective design.

## Conclusion

The court sustained a jury verdict imposing strict liability for an allegedly non-crashworthy vehicle design, applying New Jersey’s risk–utility approach and holding that federal safety-standard compliance does not preclude a finding of defect or causation when evidence supports feasible, safer design alternatives and enhanced injury.


Dawson v. Chrysler Corp., 630 F.2d 950 (3d Cir. 1980)