Lawson v. Honeywell International, Inc.
Annotate this CasePlaintiff Pamela Lynn Lawson appealed the trial court’s grant of summary judgment to the Defendant Honeywell International, Inc., on her Mississippi Products Liability Act (MPLA) claim and her negligence claim arising from injuries she sustained when her seatbelt buckle allegedly malfunctioned during an automobile accident. On July 31, 2005, Plaintiff lost control of her 1999 Jeep Cherokee while driving from Clara to Waynesboro, Mississippi. The vehicle veered off the highway and rolled over several times before coming to a stop. Plaintiff claimed that, although she had her Gen-3 seat belt buckle correctly fastened at the time of the accident, a defective design in the buckle caused it to malfunction and disengage, resulting in her ejection from the vehicle. Plaintiff alleged she suffered severe injuries as a result. She filed this action against Honeywell whom she alleged originally designed the Gen-3 seat belt buckle before selling it to Chrysler in the mid-1990s. Upon review, the Supreme Court affirmed the trial court’s grant of summary judgment as to Plaintiff's MPLA claim, finding Honeywell was not the "manufacturer" of the buckle for purposes of liability under the MPLA. However, the Court reversed the trial court’s grant of summary judgment as to Plaintiff's negligence claim, and remanded for trial, as the MPLA does not preclude common-law claims of negligence against a nonmanufacturing and nonselling designer of a product.
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