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Arizona Supreme Court limits strict liability for missing optional safety tech
The unanimous ruling in Maywald vs. Toyota says plaintiffs must separately prove a defect and that the design was unreasonably dangerous, not just that a safer alternative existed.
Arizona's Supreme Court issued a unanimous decision narrowing when manufacturers can be hit with strict product liability for the absence of optional safety features, with implications for manufacturers, insurers, and product liability coverage, according to Risk & Insurance.
In Maywald vs. Toyota, decided July 7, 2026, the case stemmed from a December 2019 crash on State Route 77 in Arizona involving a 2019 Toyota 4Runner that lacked a lane departure warning (LDW) system. The drivers, Shawn and Tanya Maywald, sued Toyota alleging the vehicle was defectively designed because it did not include LDW technology, and Shawn Maywald suffered serious injuries in the head-on collision after another driver fell asleep and drifted across the center line.
Risk & Insurance reports the court focused on two key issues, including whether strict product liability requires separate showings that a product is both defective and unreasonably dangerous. The decision reaffirmed that defect and unreasonable danger are distinct elements, not one combined inquiry, and that the risk or benefit analysis must be applied properly rather than based on hypothetical comparisons to an alternative design.
Toyota argued the 4Runner was not defective because drivers retain responsibility to stay awake and in their lane, and that any risk/benefit analysis should focus on the product as designed. The court ruled in Toyota's favor.