391 F.2d 495 (8th Cir. 1968)
Larsen v. General Motors Corp.
Whether an automobile manufacturer owes a duty to design a vehicle to be reasonably safe in foreseeable collisions and can be held liable for enhanced injuries caused by an unreasonably dangerous design even when the defect did not cause the initial accident.
A manufacturer has a duty to use reasonable care in the design of its product to avoid subjecting users to an unreasonable risk of injury in foreseeable uses and misuses, including the foreseeable occurrence of automobile collisions. While the manufacturer is not an insurer and need not design an accident-proof vehicle, it may be liable in negligence (and, by later doctrine, in strict liability) for design defects that proximately cause or enhance occupant injuries during a collision. Liability is limited to the extent of the enhanced injuries that are attributable to the design defect, and difficulties in apportioning damages do not bar recovery.
Yes. Automobile manufacturers have a duty to design vehicles that are reasonably safe in the event of foreseeable collisions, and they may be held liable for injuries enhanced by negligent design even if the defect did not cause the accident. The judgment for the manufacturer was reversed and the case remanded.
Larsen is the leading case establishing the crashworthiness doctrine, now widely accepted across jurisdictions. It teaches core tort concepts—duty based on foreseeability, design-defect negligence, proximate cause for enhanced injuries, and apportionment of damages—within the practical context of automotive safety. The case catalyzed industry-wide adoption of occupant-protection features (e.g., collapsible steering columns, energy-absorbing interiors, later airbags and improved restraint systems) and remains a cornerstone in products-liability courses and litigation involving safety design, risk-utility balancing, and the limits of manufacturer responsibility.