Martin vs. Polaris Inc. et al

Case Background

On September 15, 2022, Plaintiff Zachary Tyler Martin filed a Product Liability lawsuit in the District Court of Tennessee Eastern (Case number: 3:22cv322). District Judge Curtis L. Collie assigned the case and referred it to Magistrate Judge Jill E. McCook.

Cause

On September 17, 2021, Zachary Tyler Martin, a 27-year-old Tennessee resident, was riding as a passenger in his friend’s 2017 Polaris RZR XP 1000 EPS utility terrain vehicle (UTV). The RZR XP 1000 EPS was a two-seater sport UTV designed for off-road use and reached speeds over 60 miles per hour. During operation, the vehicle flipped onto its passenger side. The forces from the rollover caused Martin to lose his grip on the “passenger hand hold,” a T-shaped bar with hand grips located in front of the passenger seat. As a result, Martin’s right arm was ejected from the vehicle’s protective structure.

Polaris Inc., Polaris Industries Inc., and Polaris Sales Inc. designed, manufactured, assembled, and sold the RZR XP 1000 EPS. They did so without sufficient occupant protection systems, such as cab nets or doors. These systems were necessary to prevent ejection during rollover accidents. The vehicle’s owner’s manual acknowledged the risk of rollover and ejection injuries, stating that the Rollover Protective Structure (ROPS) helps prevent occupant ejection when used with seat belts and cab nets or doors. However, Polaris sold the vehicle without these crucial safety features.

Instead of providing proper containment systems, Polaris instructed users to “keep a firm grip on the steering wheel or hand holds and brace yourself” to avoid ejection during a rollover. This instruction proved ineffective given the speed and forces involved in Martin’s crash. The complaint alleged that Polaris knew or should have known that merely gripping the hand hold could not prevent ejection in a rollover event.

Injuries

When the RZR XP 1000 EPS rolled over, Martin’s right arm was crushed by the vehicle’s roll cage. The severe traumatic injury led to the amputation of his right arm below the elbow. This catastrophic injury resulted in permanent disability and disfigurement for Martin.

Damages

As a result of the accident and amputation, Martin suffered severe physical injuries, permanent disfigurement, emotional distress, pain and suffering, loss of enjoyment of life, lost wages, diminished earning capacity, and incurred substantial medical expenses for treatment and procedures. He sought $10 million in compensatory damages.

Key Arguments and Proceedings

Legal representation

  • Plaintiff(s):Zachary Tyler Martin
    • Counsel for Plaintiff: Dan C. Stanley| Eric Byron Foust | Gilbert M. Roberts
    • Experts for Plaintiff(s): Tyler A. Kress
  • Defendant(s):Polaris Inc. |  Polaris Industries Inc. | Polaris Sales Inc.
    • Counsel for Defendants: Eric T. Presnell| Russell Brandon Bundren | Casey Leigh Miller
    • Experts for Defendant(s): Manuel Meza Arroyo | Gary Rogers | Todd Hoover

 

Claims

Martin filed several claims against Polaris in his Product Liability lawsuit:

Strict Product Liability: Martin alleged that the RZR XP 1000 EPS was defective and unreasonably dangerous due to its lack of adequate rollover protection and occupant containment systems. He claimed Polaris failed to properly design the vehicle to prevent ejection during foreseeable rollover accidents.

Breach of Express and Implied Warranties: The complaint asserted that Polaris expressly and implicitly warranted that the RZR XP 1000 EPS was of merchantable quality, safe to use, and fit for its intended purposes. Martin claimed these warranties were breached due to the vehicle’s defective and dangerous condition.

Negligent Misrepresentation: Martin alleged that Polaris negligently misrepresented that users could avoid ejection during a rollover by gripping the passenger hand hold. He claimed that the company made this representation without reasonable grounds for believing it to be true. He emphasized the forces involved in rollover accidents as a key factor.

Martin also claimed that Polaris failed to adequately test the vehicle, ignored known risks, and recklessly marketed a product they knew or should have known was dangerous. He alleged that Polaris prioritized profits over safety by selling high-powered sport UTVs without proper occupant protection systems.

Defense

In their Answer, Polaris denied most of the allegations made by Martin. They admitted to certain factual points, such as their corporate structures and locations, but contested claims about product defects, negligence, and liability. Polaris asserted that the 2019 RZR XP 1000 vehicle in question was designed and manufactured in accordance with applicable regulations and standards. They claimed the vehicle was reasonably safe and not defective.

Polaris raised several affirmative defenses, arguing that Martin’s complaint failed to state a claim upon which relief could be granted. They invoked protections under the Tennessee Products Liability Act and asserted compliance with federal and state regulations. They also raised defenses of comparative fault, misuse, alteration, improper maintenance, and failure to follow instructions. Additionally, Polaris challenged the validity and constitutionality of any potential punitive damages claims. They reserved the right to amend their Answer and add defenses as the case progressed. Finally, Polaris demanded a jury trial on all triable issues and requested dismissal of the complaint with prejudice.

Expert Testimony

Polaris designated three expert witnesses to testify in their defense. Manuel Meza Arroyo, a human factors consultant, was chosen to provide testimony on alcohol intoxication and sleep deprivation, addressing potential contributing factors to the incident. Gary Rogers and Todd Hoover, engineering and accident reconstruction consultants, were selected to testify about the incident that caused Martin’s injuries and the safety of the vehicle. These experts were expected to provide technical analysis and insights into the accident’s circumstances and the vehicle’s design and performance.

 Jury Verdict

On August 20, 2024, the Court rejected all three counts of the Plaintiff’s case. As a result, it did not address the duties of the Plaintiff or Adams, nor did it consider the issue of damages. The Court entered judgment in favor of the defense in a Product Liability Lawsuit.

Court Documents:

Available Upon Request