DOMINGUE v. FORD MOTOR COMPANY

Kristen and Casey Domingue were in a Ford truck that was struck by another vehicle, and the truck's passenger airbag did not deploy, seriously injuring Kristen's head, neck, and spine. They sued Ford in federal court in Georgia, claiming the truck's airbag and restraint system were defectively designed and manufactured. During the lawsuit, the Domingues asked the federal judge to keep out any evidence about whether they were wearing seatbelts, citing a Georgia law that limits how seatbelt evidence can be used in court. Ford argued it needed to discuss seatbelts to defend its airbag design, and that shutting out all seatbelt evidence would be unconstitutional. The federal court asked the Supreme Court of Georgia to clarify what the state seatbelt statute actually covers. The court answered that the law only blocks evidence of an occupant's failure to wear a seatbelt from being used against them on issues of fault or damages. It does not block evidence that seatbelts exist in the vehicle or evidence about the seatbelt's design and compliance with safety standards. But it does block evidence of nonuse of a seatbelt, even when a manufacturer wants to use it as part of its own defense.

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

The ruling shapes how product-liability lawsuits against car makers proceed in Georgia and federal courts here. Manufacturers can still discuss seatbelt design and existence when defending airbag or restraint-system claims, but they cannot point to a victim's failure to buckle up, giving injured Georgians more protection from that argument.

Certified questions answered

1. The court read the text of OCGA § 40-8-76.1(d), Georgia's seatbelt statute, and found that its restrictions on evidence apply only when the evidentiary trigger is met: an occupant's 'failure...to wear a seat safety belt.' If that specific fact is not what's being offered, the statute's limits do not apply.
2. Because evidence that a vehicle simply has seatbelts, or evidence about how a seatbelt is designed and whether it meets federal safety standards, is different from evidence that a person failed to buckle up, the court concluded the statute does not block that kind of evidence.
3. The court rejected the Domingues' argument that older Court of Appeals cases (King and Crosby) and a federal district court case (Denton) required broader exclusion of all seatbelt-related evidence, explaining those cases addressed only nonuse evidence and relied improperly on an uncodified bill caption that cannot override the statute's plain text.
4. Applying the same textual analysis, the court found that the statute's language contains no exception for manufacturer-defendants or for particular types of lawsuits, so evidence of an occupant's failure to wear a seatbelt is barred for the purposes listed in the statute even when a manufacturer wants to use it as part of its defense.
5. The court declined Ford's request to find the statute unconstitutional as applied, explaining that the canon of constitutional doubt, which lets courts choose a constitutional reading only when a law has more than one plausible meaning, could not apply because the statute's text was clear, and that Ford's constitutional claims were not yet ripe given the early stage of the case.

• seatbelt statute
• Ford airbag lawsuit
• certified question
• product liability defense
• evidence admissibility