Bresnahan

Defendants Chrysler Corporation and Barish Chrysler (collectively Chrysler) appeal from judgment after jury trial in a product liability case, awarding plaintiff Mary Bresnahan $49,650 in damages for injuries she suffered when the air bag in her 1988 Chrysler LeBaron convertible deployed after she rear-ended another car. Chrysler contends that the court erred in instructing the jury on the consumer expectations test of design defect, and that the general verdict, rendered upon submission of that theory and also those of risk-benefit design defect and product defect by failure to warn, is unsupported by substantial evidence. The judgment must be affirmed because, Chrysler having eschewed a special verdict, the jury’s implied finding of liability for failure to warn is supported by substantial evidence.

Statement

About 6 p.m. on Sunday, June 3, 1990, plaintiff, age 50 and 5 feet 8 inches tall, was driving her LeBaron, equipped with a driver’s side air bag, east on Washington Boulevard in the neighborhood of Marina Del Rey, at between 25 and 30 miles per hour. Plaintiff was wearing her seat belt. She was seated close to the steering wheel, less than a foot away from its…