DOMINGUE v. FORD MOTOR COMPANY

Casey and Kristen Domingue were badly hurt when a Jeep struck their Ford pickup and the passenger-side airbag failed to deploy, sending Kristen into the windshield. They sued Ford Motor Company for negligence and defective design of the airbag restraint system. During the lawsuit, the Domingues asked the federal trial court to keep out any evidence about whether they wore seatbelts, citing Georgia's seatbelt statute. Ford argued it needed to discuss seatbelts, seatbelt design, and even the Domingues' seatbelt use to defend against the design-defect claim, and that shutting that evidence out would be unconstitutional. The federal court asked the Supreme Court of Georgia three questions about how far the seatbelt statute reaches. The court answered that the statute only restricts evidence of an occupant's failure to wear a seatbelt for the specific purposes listed in the law; it does not touch evidence that seatbelts exist in a vehicle or evidence about seatbelt design and safety standards. But it does bar evidence of seatbelt nonuse itself, even when a manufacturer wants to use it as part of its defense.

OCGA § 40-8-76.1(d) only restricts evidence of an occupant's failure to wear a seatbelt for the purposes the statute lists; it does not bar evidence that seatbelts exist in a vehicle or evidence about seatbelt design and compliance with federal safety standards, but it does bar seatbelt-nonuse evidence even when raised by a defendant-manufacturer's defense.

The ruling shapes how product-liability and car-accident lawsuits are litigated across Georgia. Manufacturers can still introduce seatbelt design and safety-standard evidence, but they cannot tell juries a passenger simply wasn't buckled in, which affects trial strategy for injury victims, insurers, and automakers alike.

Certified questions answered

1. The court read the text of Georgia's seatbelt statute (OCGA § 40-8-76.1(d)) closely, following the rule that a statute's plain and ordinary language, read as an everyday English speaker would understand it, controls its meaning.
2. It found that the statute's restrictions on evidence only apply when the specific fact at issue is 'the failure of an occupant of a motor vehicle to wear a seat safety belt'; if that fact isn't what's being offered, the statute's limits don't kick in.
3. Applying that rule, evidence that seatbelts merely exist in a vehicle, and evidence about seatbelt design and compliance with federal safety standards, are different facts from seatbelt nonuse, so the statute does not block either type of evidence.
4. The court rejected relying on older Court of Appeals cases and a legislative caption to broaden the statute's reach, explaining that a bill's preamble or caption cannot override the plain wording of the enacted law itself.
5. Because the statute's text draws no exception for any type of lawsuit or any party, the court held that evidence of an occupant's actual seatbelt nonuse remains barred for the statute's listed purposes even when a vehicle manufacturer wants to use it as part of its own defense.
6. The court declined to rule on Ford's claim that this reading is unconstitutional as applied, explaining that the constitutional-avoidance canon doesn't apply to a statute with only one plausible reading, and that the constitutional question wasn't yet ripe given how early the case was in the litigation.

• seatbelt statute
• products liability lawsuit
• airbag defect claim
• evidence admissibility
• certified question