$56 millionSettlementPaid

Autoliv Settles $127 Million Seatbelt Defect Judgment for $56 Million After Abandoning Its Appeal

Settlement · U.S. District Court for the Northern District of Georgia, Atlanta Division · 2023

After trial: Settled and paid. Autoliv appealed to the Eleventh Circuit in November 2022 but abandoned its appeal on July 27, 2023 and paid $56 million to settle: $42 million to Jamie Andrews and $14 million to the State of Georgia.

Won by Butler Prather LLP.

On April 12, 2013, Micah Andrews, 38, died on Interstate 575 north of Atlanta when he swerved to miss a snapping turtle in the road, ran off the shoulder into trees at about 35 miles an hour, and was killed inside a crash he should have survived: his airbag did not deploy and his Autoliv designed seatbelt spooled out about 20 inches of webbing, letting his face hit the steering wheel hub hard enough to fracture the base of his skull. His widow, Jamie Andrews, sued Autoliv and Mazda in 2014, Mazda settled its own part of the case confidentially in June 2016, and Jim Butler of Butler Prather LLP tried the case with co counsel to a bench verdict before U.S. District Judge Steve C. Jones, who found the seatbelt defectively designed and entered a $127,019,343.40 judgment at the end of December 2021, including $100 million in punitive damages. Autoliv appealed to the Eleventh Circuit, arguing the punitive award was excessive under Georgia law, then abandoned that appeal and paid $56 million to close the case on July 27, 2023, of which $42 million went to Jamie Andrews and $14 million went to the State of Georgia, which had claimed a share of the punitive award.

What happened

Micah Andrews was 38 years old on April 12, 2013, driving home on Interstate 575 north of Atlanta after a shift at the Georgia Aquarium. A large snapping turtle was in the roadway. He made a hard right steer to miss it, ran off a steep shoulder, and hit a stand of small trees head on at roughly 35 miles an hour. The crash itself was not severe enough to have been fatal. What killed him was what happened inside the car. The airbag did not deploy. The driver's seatbelt, made by Autoliv, spooled out about 20 inches of webbing instead of locking, and he was carried forward into the steering wheel with full force. The wheel's grip pattern was imprinted on his face, the base of his skull fractured, and he died at the scene.

His widow, Jamie Andrews, took over as administrator of his estate and sued Autoliv and Mazda in 2014. The claim was that the seatbelt's retractor mechanism was defectively designed, allowing far more webbing to pay out than a properly functioning belt should release in a frontal impact, and that a working belt would have held him back from the wheel. Mazda, whose airbag system also failed to deploy, settled its own part of the case confidentially in June 2016 and took no part in the trial, leaving Autoliv as the sole remaining defendant.

The case took more than seven years to reach trial. By consent of both sides it was tried without a jury, before U.S. District Judge Steve C. Jones in Atlanta, from October 4 to October 13, 2021. In a judgment entered at the end of December 2021 and reported in the first days of January 2022, Judge Jones found that the seatbelt's design was defective and that the defect caused Micah Andrews's death. He awarded $19,343.40 in special damages, $2 million for pain and suffering, and $25 million for the full value of Andrews's life under Georgia's wrongful death statute. On top of that, the judge imposed $100 million in punitive damages, finding Autoliv's conduct showed a conscious indifference to consequences, for a total judgment of $127,019,343.40.

The court apportioned the compensatory damages evenly between Autoliv and Mazda, so Autoliv's share of that part came to about $13.5 million, and the full punitive award was assessed against Autoliv alone. Its own exposure was therefore roughly $113.5 million. In October 2022, Judge Jones added about $4.7 million in prejudgment interest on top of that. Autoliv had already asked the district court in January 2022 to undo the punitive award, arguing that Georgia law required proof of willful misconduct before punitive damages could be imposed at all and that $100 million was excessive regardless. When that failed, it appealed to the Eleventh Circuit on November 1, 2022, and Jamie Andrews cross-appealed. Alston & Bird joined Autoliv's trial counsel from Ballard & Feagle for the appeal; Bondurant, Mixson & Elmore joined the Andrews side alongside Jim Butler.

The appeal never reached a ruling. On July 27, 2023, with the case still pending at the Eleventh Circuit, Autoliv abandoned it and paid $56 million to close the matter, roughly half of what it owed with interest. Of that amount, $42 million went to Jamie Andrews and $14 million went to the State of Georgia, which had claimed a share of the punitive damages under Georgia's product liability statute. The finding that Autoliv's seatbelt was defectively designed, the finding that took eight years and a full trial to establish, was never disturbed by any court.

Sources

This account is drawn from contemporaneous public reporting and the court record.

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