Vehicle manufacturer Tesla has won dismissal of a product liability lawsuit claiming that a defective touchscreen in a 2021 Tesla caused an accident.
Judge Nelson Roman in federal district court in New York granted Tesla summary judgment because the woman bringing the defect claim failed to provide any expert testimony to back up her allegation that a touchscreen malfunction caused her to lose control of the vehicle.
Products-liability claims involving complex software, electronic interfaces, and vehicle-control systems require competent expert testimony to establish defect, according to the court.
But the plaintiff offered no expert testimony to support her claims under liability theories of manufacturing defect, design defect, failure to warn, or breach of the implied warranty of merchantability. Instead, she relied solely on her own testimony to support her claims.
As a result, the judge found she failed to raise a genuine dispute of material fact, and granted Tesla summary judgment.
The Accident
Robyn Nicole Wilson-Wolf was driving her 2021 Tesla Model 3 on March 12, 2022, on Interstate 87 in Yonkers, New York. The investigating police officer recorded snowy and icy road conditions. The police accident report reflected that the vehicle hydroplaned, struck a center median, crossed back over the travel lanes, and struck a second median before coming to rest. The officer further concluded that unsafe speed and an unsafe lane change contributed to the crash.
Wilson-Wolf did not dispute the existence of winter conditions but maintained that the police report did not consider the role she alleges that a touchscreen malfunction played in her loss of vehicle control. She challenged the police conclusions, asserting that the officer was not present at the time of the crash and did not inspect the vehicle for software-related issues.
She alleged that the crash occurred because the vehicle experienced a “frozen screen,” during which “the screen went black, and all alerts stopped working,” causing the vehicle to “not function properly.”
Full Control
Tesla countered that its representative who reviewed vehicle diagnostic data from the time of the crash found no evidence that the touchscreen froze or blacked out. Tesla further maintained that even if the touchscreen were to freeze, the driver would retain full control over steering, braking, and acceleration
But Wilson-Wolf disputed the reliability and completeness of that data. She did not dispute that core driving functions remained mechanically available but argued that the diagnostic logs do not capture every malfunction and that resets performed before the crash may have erased relevant information. She contended that secondary features—such as windshield wipers, turn signals, alerts, and the speed display—were unavailable, impairing her ability to respond safely to road conditions.
Tesla further contended that vehicle data and the police report both indicated that the vehicle hydroplaned before striking the median. Wilson-Wolf maintained that hydroplaning did not negate Tesla’s responsibility for an alleged touchscreen defect and asserted that the loss of touchscreen-controlled features made it more difficult for her to regain control in hazardous conditions.
She maintained that Tesla should be liable for her injuries and brought an action asserting product liability claims sounding in strict liability, negligence, and breach of the implied warranty of merchantability.
Missing Testimony
Judge Roman noted that to succeed in her case Wilson-Wolf had to not only show that a specific touchscreen unit malfunctioned—satisfying the requirement that the defect affected a particular product—but also prove that the alleged malfunction caused the accident.
Wilson-Wolfe failed to prove any of her claims.
“These questions involve the operation of software, electronic interfaces, integrated safety systems, and their interaction with vehicle dynamics under variable road and weather conditions. Such issues are beyond the understanding of an ordinary juror, and cannot be established through lay testimony or speculation,” the judge wrote.
Wilson-Wolf designated no expert; offered no evidence on the touchscreen’s design, feasibility of a safer alternative, or risk–utility considerations; and provided nothing sufficient to exclude alternative, non-defect-related causes of the accident, according to the court. She further failed to identify any specific, actionable warning deficiency or to demonstrate that an additional or different warning would have prevented her injuries or vehicle crash.
Because Wilson-Wolf failed to raise a genuine dispute of material fact under any theory of liability, the judge ruled Tesla was entitled to judgment. He also denied Wilson-Wolf’s request for additional discovery.
Topics Trends Personal Auto Tesla
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