A manufacturer's annual production period that includes January 1 of a calendar year. If the manufacturer has no annual production period, the model year is the calendar year itself.
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Presidential Term and Model Designation
Ming Ma purchased a vehicle labeled as the 2024 model year from Marathon Logistics. The manufacturer began its annual production period in late 2023 so that the period included January 1 of the calendar year. Marathon's records confirmed the designation satisfied the definition of model year.
Sham Document Involving Model Year
Musa Mensah signed a document reciting it as his last will that listed a 2025 model year truck among assets. The manufacturer had no annual production period, so the model year was the calendar year 2025 itself. Extrinsic evidence revealed the document was created only to induce financing.
Matthew Martinez assigned all rights under a supply contract for 2023 model year delivery vans to Momentum Capital. The manufacturer's annual production period included January 1 of the calendar year. Momentum accepted the assignment and thereby promised performance to the original buyer.
Self-Defense Claim Over Model Year Dispute
Marcus Mitchell defended his 2022 model year sports car against an attacker. The manufacturer had begun its annual production period before January 1 of the calendar year. The court measured the intended harm against the serious bodily harm standard to determine privilege.
Preemption of State Model Year Rules
Mariam Mansour sued a manufacturer alleging that the 2018 model year sedan failed to meet state safety standards. Federal motor vehicle regulations governing the same model year preempted the state claim. The court dismissed the action because the federal standard controlled the design choice.
Geier v. American Honda Motor Co.529 U.S. 861, 874–75 (2000)
In 1987, petitioner Alexis Geier, then four months old, was a passenger in a 1987 Honda Accord that crashed into a tree. The car was equipped with manual shoulder and lap belts but had no airbag. The lap and shoulder belt did not prevent Alexis from striking her head on the dashboard, and she suffered serious injuries as a result.
Alexis and her parents sued the car's manufacturer, American Honda Motor Company, Inc., and its American distributor, Honda of America Manufacturing, Inc., in the United States District Court for the District of Columbia. They claimed that American Honda had designed its car negligently and defectively because it lacked a driver's side airbag. American Honda moved for summary judgment on the ground that the National Traffic and Motor Vehicle Safety Act of 1966 and FMVSS 208 preempted the lawsuit.
The District Court dismissed the lawsuit. The Court of Appeals for the District of Columbia Circuit affirmed the dismissal. The Supreme Court granted certiorari to decide whether the Act or the safety standard preempts a no-airbag lawsuit.
FMVSS 208, promulgated under the Act, required auto manufacturers to equip some but not all of their 1987 and later model vehicles with passive restraints. The standard required manufacturers to equip 10 percent of their 1987 vehicles, 25 percent of their 1988 vehicles, 40 percent of their 1989 vehicles, and 100 percent of their 1990 and later vehicles with one of several different passive restraint systems, including airbags, automatic safety belts, or other passive restraints providing at least the same level of crash protection.
Madison Meyers purchased a 1960 model year automobile whose wheel collapsed due to a latent defect. The manufacturer began its annual production period before January 1 of the calendar year. The court held the maker liable to the ultimate user despite absence of privity.
MacPherson v. Buick Motor Co.217 N.Y. 382, 111 N.E. 1050
The defendant Buick Motor Company manufactured automobiles and purchased ready-made wheels from the Imperial Wheel Company of Flint, Michigan. The Imperial company had furnished the defendant with eighty thousand wheels, none of which had proved defective prior to this incident. The defendant sold one such automobile to a firm of automobile dealers in Schenectady, who in turn sold the car to the plaintiff.
While the plaintiff was driving the automobile at a speed of only eight miles an hour, a wheel collapsed because it was made of defective wood whose spokes crumbled into fragments. The plaintiff was thrown out and injured. The wheel had been bought from the outside manufacturer rather than produced by the defendant.
Evidence showed that the defects could have been discovered by reasonable inspection, which the defendant omitted. There was no claim that the defendant knew of the defect and willfully concealed it. The car was designed to go fifty miles an hour. It had seats for three persons.
The plaintiff commenced an action for negligence against the defendant. The case was tried to a jury. The New York Court of Appeals affirmed the judgment with costs.
How is model year determined when a manufacturer has no annual production period?
The model year is the calendar year itself when no annual production period exists.
32 N.J. 358, 161 A.2d 69 (1960)
…and the independents 6.5%. Standard & Poor (Industrial Surveys, Autos, Basic Analysis, June 25, 1959) 4109. And for the same year the “Big Three” had 86.72% of the total passenger vehicle registrations. Automotive News , 1959 Almanac (Slocum Publishing Co., Inc.) p. 25. The gross inequality of bargaining position…