Pavoni v. Chrysler Group

Summary judgment may be granted where no genuine issue of material fact exists, after reviewing the case in the light most favorable to the nonmoving party.

Roy and Rose Coats were found dead in their garage on February 27, 2001. Rose, who was found between the open driver’s door and the garage door frame suffocated to death, while Roy, who was found underneath his wife, died of natural causes. The Coats' children (“Pavoni”) allege a “false park” defect in the automatic transmission of the Coat's Grand Caravan automobile caused the Coat's deaths. Specifically, they alleged that when Rose exited the vehicle, she believed the car was in park. However, the “false park” defect caused the car to self-shift into reverse, and begin moving backwards causing the Coats to be pinned, resulting in their deaths. In response to Chrysler’s motion for summary judgment, Pavoni submitted a declaration from their design defect expert who affirmed Pavoni’s allegations that the defect, more likely than not, caused the Coats’ deaths. The district court granted Chrysler’s motion for summary judgment, finding that facts asserted by Pavoni’s expert were insufficient in establishing a causal connection between Chrysler and the deaths. On appeal, the Ninth Circuit reviewed the district court's granting of Chrysler’s motion for summary judgment. An issue of material fact is genuine where a reasonable jury could find in favor of the nonmoving party. Therefore, in light of the nonmoving party, the panel found that genuine issues of material fact existed as to whether a “false park” defect in the Coats’ Grand Caravan caused the deaths of Roy and Rose Coats. REVERSED and REMANDED in part; and VACATED in part.