## Facts

- Grace Burke ran a stop sign in Clinton, Iowa, and collided with a vehicle driven by Glen Jahn.
- Jahn was driving a Hyundai Elantra; the driver-side front airbag allegedly failed to deploy.
- Jahn sustained severe injuries, including multiple fractures and an alleged closed-head injury.
- Jahn settled with Burke and her insurer before suing Hyundai.
- The Jahns sued Hyundai on res ipsa loquitur, strict liability, and breach of warranty theories, alleging the airbag defect caused enhanced injuries beyond those from the initial collision.
- The Jahns conceded Burke was a “released party” under Iowa’s Comparative Fault Act and that her negligence proximately caused the accident and Jahn’s injuries.
- In a federal diversity action, the U.S. District Court for the Southern District of Iowa certified two questions of Iowa law to the Iowa Supreme Court concerning enhanced-injury doctrine and comparative fault.

## Issues

1. Whether Iowa should adopt Restatement (Third) of Torts: Products Liability §§ 16 and 17 governing enhanced-injury liability, including specified burden-of-proof and apportionment rules (joint-and-several liability and comparative fault).
2. Whether, under the Iowa Comparative Fault Act, a jury may compare the fault of a released party whose negligence proximately caused the accident and the plaintiff’s injuries in an enhanced-injury claim against a product defendant.

## Decision

- The Iowa Supreme Court answered “yes” to all aspects of both certified questions.
- Iowa adopted Restatement (Third) of Torts: Products Liability § 16 (enhanced harm due to product defect), including the burden allocations described in § 16(b) and § 16(c).
- Iowa adopted Restatement (Third) of Torts: Products Liability § 17 (apportionment of responsibility), including its joint-and-several liability and comparative-fault framework for multiple tortfeasors in enhanced-injury cases.
- The Court held that the fault of a released party may be compared by the jury in an enhanced-injury products-liability action when that party’s negligence was a proximate cause of the accident and the plaintiff’s injuries.
- The Court issued answers to certified questions only and did not enter judgment on liability or damages.

## Legal Principles

- In an enhanced-injury (crashworthiness) claim, a product seller may be liable only for increased harm attributable to a product defect beyond the harm that would have occurred from the initial accident alone.
- Restatement (Third) § 16 supplies the governing framework for enhanced-injury liability in Iowa, including burden allocations regarding proof of enhanced harm and apportionment when precise division is difficult.
- Restatement (Third) § 17 governs apportionment of responsibility among multiple tortfeasors in enhanced-injury cases, using comparative fault and related allocation rules.
- Under the Iowa Comparative Fault Act, the jury may allocate fault among all actors whose conduct proximately caused the plaintiff’s harm, including a tortfeasor released by settlement; the release affects recovery against that party but not fault comparison.

## Conclusion

Iowa adopted Restatement (Third) §§ 16 and 17 as the governing approach for enhanced-injury products cases and held that, under Iowa’s comparative fault statute, a settling driver’s fault may still be submitted for jury comparison when it proximately caused the accident and the plaintiff’s injuries.


Jahn v. Hyundai Motor Co., 773 N.W.2d 550 (Iowa 2009)