Manufacturers Not Liable for Absence of Optional Safety Features

Manufacturers are not strictly liable for injuries caused by the absence of optional safety technology in their products, according to a unanimous decision by the Arizona Supreme Court with broad implications for manufacturers, insurers, and the product liability coverage landscape..

In a July 7, 2026 decision, Maywald vs. Toyota, the court ruled in favor of Toyota Motor Corporation, clarifying the legal standard that plaintiffs must meet when pursuing strict product liability claims.

The case arose from a December 2019 collision on State Route 77 in Arizona. Shawn and Tanya Maywald were struck head-on by a driver of a 2019 Toyota 4Runner who had fallen asleep and drifted across the center line. Shawn Maywald suffered serious injuries as a result.

The Maywalds subsequently filed suit against Toyota, alleging that the 4Runner was defectively designed because it lacked a lane departure warning (LDW) system, a technology that alerts drivers when their vehicle drifts out of its lane. Toyota did not offer LDW as either a standard or optional feature on the 2019 4Runner.

The Maywalds argued that the absence of LDW technology rendered the vehicle defective and unreasonably dangerous, exposing Toyota to strict liability for the injuries sustained. They contended that the risk/benefit analysis — one of two tests used to evaluate product safety — should weigh the risks of omitting LDW against the benefits of including it, effectively comparing the existing design to a safer alternative.

Toyota countered that the vehicle was not defective, that drivers bear the fundamental responsibility to remain awake and in their lane, and that the risk/benefit analysis must focus on the product as designed, not on hypothetical alternative designs.

The court’s analysis centered on two critical questions: whether a strict product liability claim requires separate showings that a product was both defective and unreasonably dangerous, and how the risk/benefit analysis should properly be applied.

The court firmly reaffirmed that these are two distinct elements, not a single combined inquiry. A plaintiff must first demonstrate that a product was defective — meaning it was unsafe for normal, intended use — and then separately prove that the defect made the product unreasonably dangerous. As the court stated, “strict liability is not synonymous with absolute liability,” and collapsing these two elements would expose manufacturers to liability any time a product caused an injury, regardless of whether the product itself was flawed.

Applying this framework, the court found that the 4Runner was not defective. Ordinary consumers understand that vehicles require an attentive driver to maintain lane control, and the absence of LDW technology did not render the vehicle unsafe for its intended purpose. The court also clarified that the risk/benefit analysis must evaluate the challenged design as it exists, not compare it to an alternative design. While evidence of alternative designs may inform the analysis, it cannot replace the core inquiry into whether the product as sold posed unreasonable risks.

Because the Maywalds could not establish a threshold defect, their negligent design and loss of consortium claims also failed. The court vacated the court of appeals’ decision and affirmed the trial court’s summary judgment in Toyota’s favor.

View the full opinion here. &