## Facts

- Jerrie L. Williams bought a new Chevrolet Camaro Z-28 from Smart Chevrolet Company.
- Within days, she experienced a recurring problem: the driver’s door was difficult to close and would work loose after being shut and locked.
- Williams returned the car to Smart for repairs reporting the door problem; Smart returned it as “fixed,” but the condition persisted.
- While driving about 10 mph on a straight, level gravel road, Williams testified that the driver’s door—after being shut and locked with power locks—suddenly opened; she fell out and was injured.
- After the incident, Williams observed that three screws on the door latch were loosened; she again returned the car to Smart, but the door continued to come loose.
- Williams’s expert inspected and test-drove the vehicle, found an “alignment problem” that could cause the door to come loose, could not reproduce the door’s full opening, and testified there were no defective parts that would cause the door to fly open as described.

## Issues

1. Whether Williams presented substantial evidence that a defect in the door/latch existed when the vehicle left the manufacturer or seller and that the defect proximately caused the door to open and her injury, requiring submission of strict liability to the jury.
2. Whether Williams presented substantial evidence supporting negligence and breach of express or implied warranties sufficient to avoid directed verdicts for the dealer and manufacturer.

## Decision

- The Arkansas Supreme Court affirmed directed verdicts for Smart Chevrolet and General Motors.
- Even viewing the proof most favorably to Williams, the court held the evidence did not rise above suspicion or conjecture on defect and causation.
- Because the defect/causation proof was insubstantial, Williams’s negligence and warranty theories also failed.

## Legal Principles

- On review of a directed verdict, evidence is viewed in the light most favorable to the nonmovant, giving it the highest probative value and reasonable inferences; a directed verdict stands if the proof is so insubstantial that a jury verdict would have to be set aside.
- “Substantial evidence” must be forceful enough to compel a conclusion and move beyond suspicion or conjecture; bare conclusions without supporting facts are not substantial evidence.
- In strict product liability, the plaintiff must produce evidence from which a factfinder could conclude: (1) the product was in a defective condition that was unreasonably dangerous, (2) the defect existed when it left the defendant, and (3) the defect proximately caused the injury.
- Defect and causation may be shown circumstantially, but the occurrence of an accident alone is insufficient; the plaintiff must sufficiently negate other reasonable causes not attributable to the defendant.
- Expert testimony that fails to identify a defect or replicate the alleged failure may leave the plaintiff’s proof speculative, supporting judgment as a matter of law.

## Conclusion

Because Williams could not provide substantial evidence that a defect attributable to the manufacturer or dealer existed at the time of sale and caused the door to open—particularly in light of expert testimony identifying no defective parts and the failure to exclude other reasonable causes—the court held the case could not go to the jury and affirmed the directed verdicts on strict liability, negligence, and warranty claims.


Williams v. Smart Chevrolet Co., 292 Ark. 376, 730 S.W.2d 479 (Ark. 1987)