## Facts

- Norma E. Pruitt, age 75, drove a 1991 Chevrolet Beretta manufactured by General Motors Corporation (GMC) with her seat belt and shoulder harness buckled.
- Pruitt made a left turn at an intersection and collided with an oncoming vehicle; the driver-side air bag deployed immediately.
- Pruitt suffered three fractures of her lower mandible requiring surgery and incurred medical expenses of $66,224.
- Pruitt had been edentulous since age 38, resulting in extreme bone atrophy; medical evidence described her jaw as unusually weak and fragile.
- Trial evidence conflicted on whether Pruitt would have suffered the jaw injuries absent air-bag deployment.
- Pruitt sued GMC under strict products liability, alleging (1) a design defect because the air bag deployed in a low-speed collision and (2) inadequate warnings.

## Issues

1. Whether the trial court erred by refusing to instruct the jury on the consumer expectations test for design defect in an air-bag deployment case.
2. Whether the trial court erred by excluding evidence of GMC’s postmanufacture air-bag warnings.

## Decision

- The Court of Appeal affirmed the judgment for GMC.
- The trial court properly instructed on design defect under the risk-benefit test and on failure to warn, and properly refused the consumer expectations instruction.
- The trial court did not err in excluding evidence of postmanufacture warnings.
- The jury’s special verdict finding no design defect and no warning defect supported judgment for GMC.

## Legal Principles

- The consumer expectations test is not appropriate where alleged defect concerns technical product-performance characteristics beyond ordinary consumer experience, such as air-bag deployment thresholds and force in particular crash conditions.
- In technically complex design-defect cases, the risk-benefit test supplies the proper framework and typically requires expert evidence on design choices and tradeoffs.
- Strict liability for design defect and warning defect focuses on the product and warnings as of the time the product left the manufacturer’s control; later-developed warnings are not required proof of defect at sale and may be excluded as irrelevant or unduly prejudicial.
- A plaintiff’s subjective expectation that a product should not cause injury does not, by itself, justify a consumer-expectations instruction when the challenged performance is technical and case-specific.

## Conclusion

The court affirmed a defense verdict in an air-bag injury case, holding that air-bag deployment performance is not measured by ordinary consumer expectations and that the jury was properly limited to risk-benefit and warning-defect theories, with postmanufacture warning evidence excluded.


Pruitt v. Gen. Motors Corp., 72 Cal. App. 4th 1480 (Cal. Ct. App. 1999)