Martinez v. Amazon.com Services, LLC

Background

Cecilia Martinez brought this product-liability action against Amazon.com Services, LLC. She alleges that she bought a decorative rhinestone steering-wheel product through Amazon in November 2020 and installed it on her 2020 Honda Civic. On October 15, 2023, she ran a red light and collided head-on with another vehicle. Martinez alleges that the crash deployed the driver-side airbag, dislodging and projecting the product through the car. One piece allegedly struck her right eye and caused complete blindness in that eye.

Martinez sued Amazon in California state court in February 2024, asserting several product-liability claims. The case was removed to the federal court on March 7, 2024. She later moved for partial summary judgment, which asks the court to decide part of a claim or defense when there is no genuine dispute about a material fact and the moving party is entitled to judgment as a matter of law.

Issues and analysis

Martinez sought judgment on three general subjects: whether strict product liability applies to Amazon; whether Amazon failed to warn her about the product; and whether seven of Amazon’s affirmative defenses could stand.

Amazon did not oppose judgment on the applicability of strict product liability. Although Amazon did not agree with the cited courts’ decisions, it conceded that those decisions could be applied to this case. The court therefore granted Martinez’s motion on that issue.

Amazon also agreed that its second affirmative defense—assumption of risk—would not completely bar Martinez’s strict-liability or negligence claims. The court explained that secondary assumption of risk is considered within comparative fault and affects damages after liability is determined. Because Amazon’s fifth defense already asserted comparative fault, the court found the second defense duplicative and allowed any secondary-assumption-of-risk argument to proceed under the fifth defense. The court granted Martinez’s motion as to the second defense. Amazon also conceded its seventh defense, which asserted that another necessary or indispensable party was missing, so the court granted the motion as to that defense as well.

The court did not enter judgment on Martinez’s failure-to-warn claims in Counts Three and Five. Martinez submitted her declaration stating that she received no warnings, while Amazon had not produced evidence showing otherwise. But discovery was still ongoing, the parties had not located the exact online product page Martinez viewed, and the materials that accompanied the product had not been established. Amazon said it needed to depose Martinez and investigate what information she reviewed and whether the product packaging had been preserved. The court concluded that further discovery was necessary and deferred summary judgment on the failure-to-warn claims.

For the same reason, the court deferred judgment on Amazon’s third and eighth affirmative defenses, which concerned whether Martinez disregarded or failed to follow warnings or instructions. Whether she did so depends on what warnings, if any, she received.

The court denied summary judgment on Amazon’s fifth and sixth affirmative defenses concerning comparative fault. Martinez argued that her negligent driving was not a substantial factor in causing her eye injury and that the product was a superseding cause. The court rejected those arguments at this stage. It reasoned that Martinez’s negligent driving undisputedly caused the collision and airbag deployment, and that the proposed exception for concurrent independent causes did not allow her to avoid comparative fault for her own injury. The court also stated that superseding cause is an affirmative defense available to a defendant-tortfeasor, not a basis for Martinez to eliminate her own comparative fault.

Finally, the court deferred judgment on Amazon’s ninth affirmative defense, which asserted that fault could be assigned to other responsible persons. Amazon said it needed discovery from the vehicle manufacturer and airbag manufacturer about possible third-party fault. The court found that Martinez had not eliminated the possibility that another party contributed to her injury.

Disposition

Judge Edward J. Davila granted in part and denied in part Martinez’s motion for partial summary judgment. The court granted the motion as to the applicability of strict product liability to Amazon and Amazon’s second and seventh affirmative defenses. The court denied the motion as to Amazon’s fifth and sixth affirmative defenses. The court deferred its ruling on Counts Three and Five for failure to warn and on Amazon’s third, eighth, and ninth affirmative defenses. The opinion does not resolve the underlying case as a whole.