## Facts

- Roberto O. Martinez, a tire-shop worker, attempted to mount a 16-inch Uniroyal Goodrich tire on a 16.5-inch multipiece rim.
- After inflation, the tire exploded during bead seating, throwing Martinez and causing severe injuries.
- The tire bore a warning instructing that a 16-inch tire should not be used on a 16.5-inch rim.
- The Martinezes alleged a design defect in the tire’s bead, asserting it was unusually prone to catastrophic failure under mismatch conditions.
- Plaintiffs presented evidence that other manufacturers used a different bead design that would have prevented the explosion and that Goodrich knew mismatching was occurring and causing serious injuries.
- Goodrich argued the accident was caused by misuse contrary to the warning and by a rim it neither designed nor manufactured, and contended the proposed alternative bead design had other drawbacks.

## Issues

1. Whether the evidence was legally and factually sufficient to prove the tire was defectively designed, including the existence of a safer alternative design.
2. Whether the mismatch mounting and warning label defeated causation or liability as misuse, or whether the design defect was a producing/proximate cause of the injury.
3. How proportionate-responsibility and settlement-credit rules applied given pretrial settlements by the rim manufacturer and the rim designer/specifier.
4. Whether the evidence supported gross negligence and punitive damages under Texas standards, and whether the punitive award required modification.

## Decision

- The Texas Supreme Court upheld the judgment imposing design-defect liability against Goodrich.
- The Court held the evidence supported a finding that the bead design was unreasonably dangerous and that a feasible safer alternative design existed that would have prevented the injury.
- The Court rejected the argument that an adequate warning categorically barred a design-defect claim where a safer alternative design was shown and the misuse was foreseeable.
- The Court found sufficient evidence of causation tied to bead failure and expert testimony that the alternative design would have avoided the catastrophic event.
- The Court addressed damages issues, including settlement credits and punitive damages, and modified aspects of the damage recovery while leaving compensatory liability intact.

## Legal Principles

- In Texas design-defect cases, the plaintiff must prove (1) an unreasonably dangerous design, (2) a safer alternative design, and (3) producing causation.
- Expert testimony can establish a safer alternative design if it supports feasibility and reduced risk without requiring the jury to speculate.
- An adequate warning does not necessarily defeat a design-defect claim when a safer alternative design is available and the risk arises from foreseeable misuse.
- Foreseeable misuse may be considered in the risk-utility analysis; manufacturer knowledge of recurring misuse can support defect and causation findings.
- Gross negligence requires evidence of an extreme degree of risk and the defendant’s actual, subjective awareness coupled with conscious indifference; punitive damages remain subject to heightened review and adjustment.

## Conclusion

The court sustained design-defect liability where evidence showed the tire’s bead design created an unreasonable mismatch-explosion risk and a feasible safer alternative bead would have prevented the injury, treating foreseeable misuse as part of the defect analysis despite warnings, while modifying aspects of damages and punitive recovery.


Uniroyal Goodrich Tire Co. v. Martinez, 977 S.W.2d 328 (Tex. 1998)