## Facts

- Mounce A. Jackson was injured in a single-vehicle crash while driving a 1992 Pontiac Grand Prix manufactured by General Motors Corporation (GM).
- The vehicle lost control on wet pavement, crossed the median and westbound lanes, and struck a tree; Jackson’s jaw struck the steering wheel.
- Jackson was wearing his seatbelt and asserted the seat was positioned as far from the steering wheel as the adjustable track allowed.
- Impact speed was estimated at 19–23 miles per hour; Jackson suffered facial fractures and later developed temporomandibular joint dysfunction.
- Jackson sued GM under the Tennessee Products Liability Act of 1978 (TPLA), alleging the seatbelt/restraint system was unreasonably dangerous.
- Jackson limited his theory to strict products liability under the TPLA’s consumer-expectation test.
- In federal district court, GM obtained summary judgment on reconsideration based on the view that ordinary consumers lack a basis to form expectations about seatbelt performance in similar accidents.
- The Sixth Circuit certified to the Tennessee Supreme Court whether a plaintiff may use the TPLA consumer-expectation test to prove a seatbelt/restraint system was unreasonably dangerous.

## Issues

1. Under the TPLA’s definition of “unreasonably dangerous,” may a plaintiff rely on the consumer-expectation test to prove defectiveness, including for a seatbelt/restraint system?
2. Is the consumer-expectation test categorically unavailable for “complex” products, requiring plaintiffs instead to proceed under the prudent-manufacturer (risk–utility) test?

## Decision

- The Tennessee Supreme Court answered the certified question “yes.”
- The Court held the consumer-expectation test is available in any products-liability claim in which a party seeks to show the product was unreasonably dangerous.
- The Court rejected a categorical limitation that would confine the consumer-expectation test to “simple” or “commonplace” products and exclude complex products such as seatbelts.
- The Court clarified that whether expert testimony is needed concerns the sufficiency of proof in a given case, not whether the consumer-expectation theory is legally permitted.
- The Court did not decide whether the seatbelt/restraint system was unreasonably dangerous, leaving application of the standard to the federal courts on remand.

## Legal Principles

- Under Tenn. Code Ann. § 29-28-102(8), “unreasonably dangerous” may be established by either of two alternative tests: (1) consumer expectation or (2) prudent manufacturer (risk–utility).
- The statute’s disjunctive phrasing authorizes proof under either test; courts may not add a product-category limitation absent statutory text.
- The consumer-expectation test may be used in any products-liability case alleging an unreasonably dangerous product, including cases involving technologically complex products.
- The need for expert evidence may arise when proving consumer expectations in particular circumstances, but complexity does not bar use of the consumer-expectation test as a matter of law.

## Conclusion

The Tennessee Supreme Court held that the TPLA permits plaintiffs to attempt to prove a product is unreasonably dangerous using the consumer-expectation test in any products-liability action, and courts cannot exclude that test solely because the product is complex; proof requirements, including any expert testimony, are case-specific.


Jackson v. Gen. Motors Corp., 60 S.W.3d 800 (Tenn. 2001)