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Clark v. Mazda Motor Corporation3/4/2003
__ P.3d __
The instant matter involves a question certified by the United States District Court for the Western District of Oklahoma in a manufacturers' products liability case. We are asked to answer the question of whether 47 O.S. 2001, §12-420 of the Oklahoma Mandatory Seat Belt Act, 47 O.S. 2001, §12-416 et seq., as interpreted in Bishop v. Takata Corp., 2000 OK 71, 12 P.3d 459, bars the admission of evidence of seat belt use or non-use, in a manufacturer's products liability crashworthiness case . The question is answered as follows: Section 12-420 does not bar the admission of evidence of the use or non-use of seat belts in a manufacturer's products liability crashworthiness case, although it prohibits introduction of such evidence to impute negligence or fault to a person who elects not to wear a seat belt.
We held §12-420 of Oklahoma's Mandatory Seat Belt Use Act did not preclude admission of evidence pertaining to seat belt use or nonuse in a manufacturers' products liability action for a defective seat belt restraint system in Bishop v. Takata Corp., 2000 OK 71, 12 P.3d 459. The Bishop matter came to us as a certified question from the United States District Court for the Western District of Oklahoma, Honorable Lee R. West. We discussed the implications of the Mandatory Seat Belt Act and concluded it protects persons in civil proceedings from connotations of fault but does not preclude admission of evidence pertaining to an automobile's design. Bishop, 2000 OK 71, -22, 12 P.3d 459, 466. In Bishop, the issue concerned the condition of the seat belt, as opposed to the conduct of the seat belt user. Bishop, 2000 OK 71, 12, 12 P.3d 459, 463. The plaintiff therein sought to introduce evidence of a defective seat belt that allegedly disengaged and caused her to be thrown from the vehicle. In the instant case, it is the defendant manufacturer who seeks to introduce seat belt evidence. Once again, as in Bishop, it is the design, construction and condition of the seat's occupant restraint system that is at issue herein, and not the conduct of the vehicle occupant who either used or elected not to use the seat belt.
Facts
The facts reported by the United States District Court are as follows. This case arises from a multi-vehicle accident in which the 1989 Mazda 626 driven by plaintiff, Stephanie Clark, (hereinafter "Clark,") crossed the center median of the H.E. Bailey Turnpike and was involved in four different collisions. In the first two, Clark's Mazda collided with a southbound pickup and the pickup's stock trailer. The third and fourth collisions occurred when Clark's Mazda was struck twice by a southbound tractor-trailer. The fourth collision ejected Clark out the back window of the Mazda, and amputated her lower left arm. Clark's impact with the pavement paralyzed her.
The facts reported to the Court establish that the safety restraint system in Clark's Mazda included a shoulder belt that engaged automatically when the driver closed the door. This shoulder belt was across Clark's torso at the time of the collisions. Clark was not wearing the manual lap belt.
An initial review of the elements essential to a successful manufacturers' products liability claim is necessary as we begin our analysis of the legal issue presented by this federal certified question. We set forth the legal blueprint for a manufacturers' products liability claim in Kirkland v. General Motors Corp., 1974 OK 52, 521 P.2d 1353. In Kirkland, we articulated three elements a plaintiff must prove and determined that upon plaintiff's proof of these elements, a manufacturer incurs strict liability. These three elements, as they pertain to a product manu
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