## Facts

- Erling David Larsen drove a 1963 Chevrolet Corvair in Michigan.
- The Corvair was involved in a head-on collision, with impact at the car’s left front corner.
- Larsen alleged the steering mechanism was thrust rearward into his head during the crash, causing severe injuries.
- Larsen did not claim the steering design caused the collision; he claimed it increased the severity of his injuries compared to safer alternative designs.
- Larsen sued General Motors Corporation alleging negligent design of the steering assembly and its placement/attachment, negligent failure to warn of a latent danger, and breach of express and implied warranties of merchantability.
- The federal district court (applying Michigan law) granted summary judgment to GM on the ground that an auto manufacturer had no duty to make a vehicle “safe” or “safer” for occupants in a collision.

## Issues

1. Whether an automobile manufacturer owes a duty of reasonable care in design to reduce foreseeable, collision-enhanced injuries even when the alleged defect did not cause the accident.
2. Whether summary judgment was proper where the plaintiff alleged a design created an unreasonable risk of injury during a foreseeable collision.

## Decision

- The Eighth Circuit reversed the summary judgment and remanded.
- The court held that collisions are a foreseeable aspect of ordinary automobile use.
- The court rejected the categorical argument that a manufacturer has no duty regarding occupant safety in collisions.
- The court concluded a negligence claim may proceed when a design allegedly subjects occupants to an unreasonable risk of enhanced injury in a crash, even if the design did not cause the crash.

## Legal Principles

- A manufacturer has a duty to use reasonable care in vehicle design to avoid subjecting users to an unreasonable risk of injury in foreseeable collisions.
- “Intended use” of an automobile includes foreseeable accidents; design duties are not limited to preventing accidents but may include reducing injury severity when accidents occur.
- Liability may be based on enhanced-injury (“second collision”/crashworthiness) theory: a defect can be actionable if it aggravates injuries, even if it did not cause the initial collision.
- The duty is one of reasonable care, not a requirement to make an accident-proof vehicle or to serve as an insurer of occupant safety.
- Where duty is recognized and material facts remain on breach and causation, summary judgment is improper and the claims should be decided by the factfinder.

## Conclusion

The court recognized that an automaker’s design obligations extend to foreseeable collisions and held that a plaintiff may pursue negligence claims for design features that allegedly increase crash injuries, reversing summary judgment and sending the case back for further proceedings.


Larsen v. Gen. Motors Corp., 391 F.2d 495 (8th Cir. 1968)