## Facts

- A 15-year-old front-seat passenger was injured in Puerto Rico when the passenger-side airbag in a 1996 Hyundai Accent deployed during a rear-end collision.
- The driver braked, leaving substantial skid marks, and the Hyundai struck a slower vehicle ahead with an estimated speed differential of roughly 30 mph.
- The passenger raised an arm to brace; the deploying airbag struck her arm, causing multiple fractures that required surgeries and left lasting scarring and reduced strength.
- The parties disputed seatbelt use; the jury found no comparative negligence.
- Technical evidence placed the collision’s barrier equivalent velocity around 14–16 mph; the airbag was designed to deploy at about 12 mph or greater.
- Hyundai’s design experts testified the deployment threshold and related design choices were driven by safety tradeoffs, including protecting unbelted occupants and meeting federal safety requirements.
- Plaintiff presented no independent design expert and relied on cross-examination and inferences to argue the airbag should not have deployed in this crash.

## Issues

1. Under Puerto Rico’s burden-shifting risk-utility test for design defects, can a plaintiff prevail where uncontroverted evidence shows the design’s overall utility outweighs its risks?
2. Is a verdict sustainable without affirmative evidence of a feasible safer alternative design, when the product operated as designed?
3. May a jury impose liability based solely on disbelief of the manufacturer’s experts or a consumer-expectations view inconsistent with Puerto Rico design-defect doctrine?

## Decision

- The First Circuit reversed the judgment for the plaintiff and directed entry of judgment for Hyundai.
- The court held the verdict was legally insufficient because the uncontradicted evidence established the airbag design’s overall utility exceeded its risks.
- The court emphasized plaintiff produced no evidence of a feasible, safer alternative design that would improve overall safety while accounting for belted and unbelted occupants and regulatory constraints.
- The court ruled that rejecting the defendant’s experts, without affirmative proof meeting the governing standard, would improperly convert the manufacturer into an insurer or apply a consumer-expectations theory not recognized as an independent design-defect basis under Puerto Rico law.

## Legal Principles

- Puerto Rico design-defect law applies a burden-shifting risk-utility framework: after a plaintiff makes a threshold showing linking design to injury, the manufacturer must prove the design’s utility outweighs its risks.
- Burden shifting does not authorize strict insurer-like liability for injuries caused by a properly functioning product.
- A plaintiff cannot satisfy the risk-utility standard merely by discrediting defense experts; the record must contain affirmative evidence supporting a finding that overall risks outweigh overall utility.
- In assessing design defect for safety devices, the risk-utility inquiry considers population-level tradeoffs, including protection for belted and unbelted occupants and compliance with applicable safety standards.
- Absence of evidence of a feasible, safer alternative design can be fatal where the only proof supports the challenged design’s overall safety justification.

## Conclusion

The court set aside a jury verdict imposing design-defect liability for injuries caused by a deploying airbag because the only competent technical evidence showed the design’s overall benefits outweighed its risks and plaintiff offered no affirmative proof of a feasible, safer alternative consistent with Puerto Rico’s risk-utility doctrine.


Quintana-Ruiz v. Hyundai Motor Corp., 303 F.3d 62 (1st Cir. 2002)