Sz Huang et al vs Tesla Inc. et al

Case Background

Plaintiff Sz Hua Huang filed the Tesla Autopilot crash lawsuit on April 26, 2019. She did so individually and as successor in interest to Wei Lun, Deceased. The lawsuit was filed in the California State Superior Court of Santa Clara County (Case number: 19CV346663). Judge Lori E. Pegg presided over the case.

Cause

On March 23, 2018, at approximately 9:27 AM, Walter Huang was driving his 2017 Tesla Model X southbound on US Highway 101 in Mountain View, California. Huang had purchased the vehicle in October-November 2017. As he approached the interchange with State Highway 85, Huang was using the Tesla’s Autopilot features, including “traffic-aware cruise control” and “autosteer lane-keeping assistance.” As the vehicle neared the paved gore area dividing the main travel lanes of US-101 from the SH-85 exit ramp, the Autopilot system steered the vehicle out of its lane. It then accelerated directly into a concrete highway median barrier.

The crash attenuator guard at the barrier had been damaged in a previous collision over 11 days prior. The State of California had not repaired it. This critical safety feature was designed to dissipate crash energy and reduce impact forces in the event of a collision. Huang’s Tesla collided with the unprotected concrete barrier at approximately 70 mph. The complaint alleges that Tesla’s Autopilot system failed to detect the barrier and that the vehicle lacked an effective automatic emergency braking system to prevent or mitigate the collision.

Injuries

Walter Huang sustained severe, fatal injuries when his Tesla Model X collided with the concrete median barrier at high speed. While the complaint does not provide specific medical details about his injuries, it states that Huang suffered fatal bodily injuries in the collision. He was pulled from the vehicle and transported to a hospital. He was pronounced dead several hours after the crash. The high-speed impact with the unprotected concrete barrier, combined with the alleged failure of the Tesla’s safety systems, resulted in injuries too severe for Huang to survive.

Damages

The plaintiffs, including Huang’s wife, children, and parents, suffered economic and non-economic damages as a result of his death. Economic damages included medical expenses incurred before Huang’s death, funeral and burial costs, and loss of his financial support and household services. Non-economic damages included loss of love, companionship, comfort, care, assistance, protection, affection, society, and moral support. The plaintiffs sought compensation for both past and future damages, as Huang’s death resulted in ongoing and long-term financial and emotional losses for his family.

Key Arguments and Proceedings

Legal representation

  • Plaintiff(s): Sz Hua Huang | Trinity Huang, a Minpr | Tristan Huang, a Minor | Hsi Keng Huang | Ching Fen Huang
  • Defendant(s):Tesla Inc. | The State of California, Department of Transportation
    • Counsel for Defendants: Daniel C Posner| Vincent Galvin | Kevin Malloy | Landa Siu Low | Rosemary Iola Love
    • Experts for Defendant(s): Lars Reinhart 

Claims

The plaintiffs brought multiple claims against Tesla Inc. and the State of California, alleging various theories of liability.

Against Tesla:

  • Negligence/Wrongful Death: The plaintiffs alleged Tesla was negligent in the design, manufacture, testing, marketing, sale, and maintenance of the 2017 Tesla Model X. They claimed Tesla failed to provide adequate instructions and warnings about the vehicle’s limitations and potential for malfunction.
  • Strict Product Liability: The complaint alleged the Tesla Model X was in a defective and unreasonably dangerous condition when it left Tesla’s possession. The plaintiffs claimed the vehicle failed to meet consumer expectations for safety and argued that safer alternative designs were feasible.
  • Negligence (Post-Sale Duty to Warn): The plaintiffs alleged Tesla knew or should have known about defects in the Autopilot system. They based this claim on previous incidents and available data. They claimed Tesla had a duty to warn owners and recall or update the vehicles to address these safety issues.

Against the State of California:

  • Dangerous Condition of Public Property: The plaintiffs alleged the State negligently failed to maintain, inspect, and repair the highway, particularly the damaged crash attenuator guard. They claimed this created a dangerous condition that increased the risk and severity of accidents at that location.
  • Failure to Discharge Mandatory Duty: The complaint alleged the State violated statutory duties to maintain safe highways and promptly repair damaged safety devices. The plaintiffs claimed this failure to comply with mandatory duties made the State liable for the dangerous condition that contributed to Huang’s death.

The plaintiffs argued that both Tesla’s allegedly defective Autopilot system and the State’s failure to maintain the roadway acted in concert to cause Huang’s fatal crash. They sought compensation for all economic and non-economic damages resulting from his death.

Defense

Tesla Inc. responded to the plaintiffs’ complaint with an answer that denied all allegations and asserted several affirmative defenses. The company denied any liability for the accident and damages claimed by the plaintiffs.

Tesla raised multiple defenses, including failure to state a cause of action, comparative fault, assumption of risk, third-party liability, and compliance with state-of-the-art standards at the time of manufacture. The company also alleged potential abuse, alteration, misuse, or improper maintenance of the vehicle after it entered the stream of commerce.

Additionally, Tesla claimed the plaintiffs failed to mitigate damages and may have failed to preserve crucial evidence. The company asserted that the plaintiffs’ claims could be barred by preemption doctrines, statutes of limitations, and lack of standing. Tesla argued it had no duty to issue a recall based on the circumstances alleged in the complaint.

The company reserved the right to raise additional defenses as they became known through discovery. Tesla demanded a jury trial on all issues raised in the case.

Expert Testimony

The plaintiffs disclosed Mark Shattuck, P.E. and Ph.D. He testified on subjects including human dynamics, biomechanics, kinematics, the defendants’ liability, and causation. On the other side, defendant Tesla disclosed Dr. Lars Reinhart. Dr. Reinhart provided expert testimony on injury causation and occupant kinematics. His testimony also covered the relationships between vehicle dynamics, occupant kinematics, and occupant injuries.

Jury Verdict

On April 28, 2024, a jury of twelve members rendered a verdict in favor of Tesla Inc. and against the plaintiffs in the Tesla Autopilot crash lawsuit stemming from the wrongful death of Wei Lun.

Court Documents:

Available Upon Request