Dallas Jury Awards $37.6 Million After Defective Seat Belt Design Leaves Rideshare Passenger Quadriplegic

On the evening of November 15, 2015, Sarah Milburn, then 27 years old, climbed into the third-row middle seat of a 2011 Honda Odyssey that her group had hired through Uber. She buckled what she believed was the seat belt. The Uber driver ran a red light. A pickup truck struck the minivan broadside, and the vehicle rolled, coming to rest on its roof. The crash broke Milburn's neck and left her a quadriplegic requiring around-the-clock care.

The central question at trial was not just what the driver did but what the seat belt did. The third-row center position in that Odyssey used a two-part restraint: a detachable shoulder strap stored on the van's ceiling that a passenger had to retrieve, anchor to the seat, and then mate with a separate lap belt. Milburn had attached the shoulder strap without completing the lap-belt connection, the same partial installation that an expert witness demonstrated to the jury. In testing conducted for the case, 50 of 53 people who were unfamiliar with the system failed to use it correctly. Fewer than ten percent got it right on the first attempt. Aldous, quoting evidence at the time, noted that wearing the belt the way Milburn wore it was more dangerous than wearing no belt at all.

Charla Aldous of Aldous Walker, together with co-counsel Brent Walker and Jim Mitchell of PayneMitchell Law Group, tried the case before Judge Tonya Parker over nine days. The plaintiff's theory was straightforward: a manufacturer's duty extends beyond federal compliance. A restraint system that real-world passengers cannot and will not use correctly is defective in design, regardless of whether it satisfies a federal minimum standard.

Honda defended on the ground that the Odyssey's seat belt met all applicable Federal Motor Vehicle Safety Standards, which under Texas law triggers a statutory presumption of nonliability. The jury rejected that defense. After nine days of testimony, it found Honda 63 percent at fault and the Uber driver 32 percent at fault, with Milburn bearing 5 percent comparative responsibility. The jury's gross award was $37.6 million. Applying the fault percentages and settlement credits, the trial court entered judgment of just under $26 million in damages and prejudgment interest.

Honda appealed. In 2021 the Dallas Court of Appeals affirmed, concluding that the evidence was sufficient for the jury to find the federal safety standard inadequate. Honda then sought review from the Texas Supreme Court. On June 28, 2024, the Supreme Court reversed and rendered a take-nothing judgment for Honda, holding that Milburn's experts had not produced legally sufficient evidence to rebut the statutory presumption under Texas Civil Practice and Remedies Code section 82.008. The court concluded that showing a design is defective does not alone establish that the underlying federal standard failed to protect the public from unreasonable risks. Milburn recovered nothing.