MAYWALD v. TOYOTA

IN THE

SUPREME COURT OF THE STATE OF ARIZONA

SHAWN MAYWALD, AN INDIVIDUAL, AND TANYA L. MAYWALD, AN
INDIVIDUAL,
Plaintiffs/Appellants,

v.

TOYOTA MOTOR CORPORATION, A JAPANESE CORPORATION; TOYOTA
MOTOR NORTH AMERICA, INC., A CALIFORNIA CORPORATION; OVERTYME,
INC., AN ARIZONA CORPORATION,
Defendants/Appellees.

No. CV-25-0009-PR
Filed July 7, 2026

Appeal from the Superior Court in Navajo County
The Honorable Melinda K. Hardy, Judge
No. S0900CV202100003
AFFIRMED

Memorandum of the Court of Appeals, Division One
No. 1 CA-CV 23-0723
VACATED

COUNSEL:

G. Lynn Shumway, Shumway Law, PLLC, Phoenix; Brent Ghelfi (argued),
Ghelfi Law Group, PLLC, Phoenix, Attorneys for Shawn Maywald and
Tanya L. Maywald.

James W. Halbrooks, Jr., William F. Auther, Amanda E. Heitz, Wendy F.
Lumish (argued), Alexander J. Egbert, Bowman and Brooke LLP, Phoenix,
Attorneys for Toyota Motor Corporation, Toyota Motor North America,
Inc., Overtyme, Inc.

Patrick X. Fowler, Ashley Wiberg, Snell & Wilmer LLP, Phoenix, Attorneys
for Amicus Curiae The Product Liability Advisory Council, Inc.
 MAYWALD V. TOYOTA
Opinion of the Court

JUSTICE BEENE authored the Opinion of the Court, in which CHIEF
JUSTICE TIMMER, VICE CHIEF JUSTICE LOPEZ and JUSTICES BOLICK,
MONTGOMERY, KING, and CRUZ joined.

JUSTICE BEENE, Opinion of the Court:

¶1 A manufacturer is liable for harm caused by a product sold
“in a defective condition unreasonably dangerous.” O. S. Stapley Co. v.
Miller, 103 Ariz. 556, 559 (1968) (quoting Restatement (Second) of Torts
§ 402A (Am. L. Inst. 1965)). In this case, we consider whether a prima facie
claim for strict product liability requires a showing that a product was both
defective and unreasonably dangerous as independent elements. We also
address the proper application of the consumer expectation test and
risk/benefit analysis used for assessing the dangerousness of a defective
product.

¶2 We conclude that a plaintiff asserting a strict product liability
claim must first establish that the product was sold in a defective condition
and, if so, that the defect rendered the product unreasonably dangerous.

¶3 The consumer expectation test and risk/benefit analysis
inform the unreasonably dangerous inquiry. The consumer expectation
test applies when an ordinary consumer, based on experience, has formed
expectations about how safely the product at issue will perform. When that
test does not apply, courts should instead employ the risk/benefit analysis,
which weighs the risks and benefits of the product as designed rather than
comparing those risks and benefits to those of an alternative design.

BACKGROUND

¶4 In December 2019, Shawn and Tanya Maywald were
traveling southbound on State Route 77 when the driver of a 2019 Toyota
4Runner, traveling northbound, fell asleep, drifted across the center line,
and collided with the Maywalds’ vehicle. Shawn Maywald sustained major
injuries from the accident.

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Opinion of the Court

¶5 Consequently, the Maywalds sued Toyota Motor
Corporation, Toyota Motor North America, Inc., and Overtyme, Inc.
(collectively, “Toyota”), alleging strict liability for design defect, negligent
design, and loss of consortium claims. The Maywalds alleged that the 2019
4Runner was defective and unreasonably dangerous because the vehicle
lacked a lane departure warning (“LDW”) system. LDW is a technology
that emits an audio, visual, or tactile alert when it detects a driver drifting
from the intended lane of travel. Toyota did not offer LDW as a standard
or optional feature for the 2019 4Runner.

¶6 Toyota moved for summary judgment, arguing that the
4Runner was not defective or unreasonably dangerous and that the
vehicle’s design did not cause the accident. The Maywalds filed
cross-motions for partial summary judgment concerning comparative fault
and the risk/benefit analysis as it applied to the 4Runner’s design. In
response, Toyota asserted that the Maywalds’ theory of liability was
fundamentally flawed insofar as it depended on the notion that the
risk/benefit analysis entails consideration of the risks and benefits of an
alternative design rather than the risks and benefits of the product’s actual
design. The superior court granted Toyota’s motions, denied the
Maywalds’ motions, and entered final judgment in favor of Toyota.

¶7 The court of appeals vacated the superior court’s grant of
summary judgment. See Maywald v. Toyota Motor Corp., No. 1 CA-CV
23-0723, 2024 WL 5165445, at *6 ¶ 29 (Ariz. App. Dec. 19, 2024) (mem.
decision). The court noted that Arizona has adopted the consumer
expectation test and the risk/benefit analysis to “determine whether a
defective product was unreasonably dangerous.” Id. at *2 ¶ 8. It then
reasoned that the consumer expectation test was inapplicable because LDW
is not sufficiently well known and widely adopted such that ordinary
consumers expect that its inclusion is required for a vehicle to perform
safely. Id. ¶ 10.

¶8 Next, the court determined that the risk/benefit analysis
applied and was not predicated on a threshold showing that the 4Runner
was defective. See id. at *3–4 ¶¶ 11–16. The court further opined that the
risk/benefit analysis is not restricted to the 4Runner as it was designed but
instead should weigh the risks of excluding LDW against the benefits of
including LDW. See id. at *4 ¶¶ 17–21. Under its risk/benefit analysis, the

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Opinion of the Court

court found that the Maywalds pleaded sufficient facts for their strict
product liability claim to survive Toyota’s motion for summary judgment.
Id. ¶ 21. The court also concluded that there were genuine issues of material
fact as to whether Toyota acted negligently when it designed the 4Runner
without LDW and whether the absence of LDW proximately caused the
accident. See id. at *5–6 ¶¶ 22–27. Finally, because the court reinstated the
Maywalds’ substantive claims, it also reinstated the Maywalds’ derivative
loss of consortium claim. Id. at *6 ¶ 29.

¶9 We granted Toyota’s petition for review to resolve whether a
strict product liability claim requires establishing that the product is both
defective and unreasonably dangerous and to clarify the proper application
of the consumer expectation test and the risk/benefit analysis. These are
matters of statewide importance likely to recur. We have jurisdiction
pursuant to article 6, section 5(3) of the Arizona Constitution.

DISCUSSION

¶10 We review the superior court’s ruling on a motion for
summary judgment de novo, viewing the facts and reasonable inferences
in the light most favorable to the non-moving party. Rosenberg v. Sanders, 256 Ariz. 359, 364 ¶ 24 (2023). Summary judgment is required “if the
moving party shows that there is no genuine dispute as to any material fact
and the moving party is entitled to judgment as a matter of law.” Ariz. R.
Civ. P. 56(a).

I.

¶11 Nearly sixty years ago, in O. S. Stapley Co., this Court adopted
the doctrine of strict product liability as set forth in Restatement § 402A,
which provides that “[o]ne who sells any product in a defective condition
unreasonably dangerous to the user or consumer or to his property is
subject to liability.” 103 Ariz. at 559–60 (quoting Restatement § 402A).
Building on that foundation, this Court later rejected a different approach
in California law and reaffirmed in Byrns v. Riddell, Inc., that a party
asserting a strict product liability claim under Arizona law must prove both
that the product was defective and that the defect rendered it unreasonably
dangerous. 113 Ariz. 264, 266–67 (1976). This two-part test was reaffirmed
in Rogers v. Unimac Co., where this Court further specified that a plaintiff
must not only prove that the product which caused the injury “was
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Opinion of the Court

defective when it left the factory, but also that such defect made the product
unreasonably dangerous and was also the proximate cause of the plaintiff’s
injury.” 115 Ariz. 304, 307 (1977).

¶12 Retaining the two-part test preserves the distinction between
a defective product and one that merely causes injury. Without the
independent requirement that the product posed an unreasonable danger,
a factfinder could conclude that any injury-causing product is defective,
effectively converting product-liability law into absolute liability. See Dart
v. Wiebe Mfg., Inc., 147 Ariz. 242, 244 n.1 (1985); Byrns, 113 Ariz. at 267
(observing that the “unreasonable danger” concept is particularly “effective
as a means of limiting the strict tort liability doctrine ‘in cases in which the
issue is the nature of the duty of a manufacturer with respect to safe design,
or in situations in which injury does not follow as a matter of course from
the defect.’” (quoting Allan E. Korpela, Annotation, Products Liability:
Product as Unreasonably Dangerous or Unsafe Under Doctrine of Strict Liability
in Tort, 54 A.L.R. 3d 352 (1973))); see also Vineyard v. Empire Mach. Co., 119
Ariz. 502, 504 (App. 1978) (noting that “strict liability is not synonymous
with absolute liability” because the latter renders a manufacturer liable
upon solely establishing that a product caused an injury).

¶13 Although Dart reaffirmed the two-part “defect” and
“unreasonable danger” test, it also blurred the distinction between those
concepts by stating that “the question of defective and unreasonably
dangerous condition” could be resolved together under a risk/benefit
analysis. 147 Ariz. at 245 (emphasis added). Nevertheless, in Readenour v.
Marion Power Shovel, this Court reiterated that proof of a defect alone is
insufficient to establish liability. 149 Ariz. 442, 447 (1986). The Court
explained that “[s]trict liability in tort is found only where the defective
condition causes the product to be ‘unreasonably dangerous.’” Id.
Readenour first defined a “defective condition” as “one which makes the
product unsafe for ‘normal handling and consumption.’” Id. (quoting
Restatement § 402A cmt. h). Next, Readenour confirmed that courts use the
consumer expectation test and the risk/benefit analysis recognized in Dart
to determine whether a product is unreasonably dangerous. Id. Thus,
Readenour reaffirmed the two-part test for strict product liability,
concluding that strict product liability applies only when a product is both
defective and unreasonably dangerous.

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Opinion of the Court

¶14 In the years that followed, however, appellate decisions
muddied that framework. The court of appeals relied on several of those
decisions in analyzing the issues presented here. One such decision was
Dillon v. Zeneca Corp., 202 Ariz. 167 (App. 2002), which the court of appeals
cited in defining the elements of a prima facie strict product liability claim.
See Maywald, 2024 WL 5165445, at *2 ¶ 7. Dillon concluded that a plaintiff
must make a singular showing that the product was in a defective condition
that rendered it unreasonably dangerous rather than first demonstrating
defectiveness and then that unreasonable danger arises from the defect. 202
Ariz. at 172 ¶ 14. In support of its conclusion, it cited this Court’s decision
in Gosewisch v. American Honda Motor Co., 153 Ariz. 400 (1987). Id. But
Gosewisch did not frame the standard that way; it held that a prima facie
case requires proof that “the product is in a defective condition and
unreasonably dangerous.” 153 Ariz. at 403 (emphasis added). By recasting
Gosewisch’s formulation, Dillon collapsed two distinct elements of a strict
product liability claim, and in doing so, misstated the governing standard.

¶15 A similar misunderstanding appears in another case the court
of appeals relied on—Golonka v. General Motors Corp., 204 Ariz. 575 (App.
2003). In Golonka, the court described two approaches for determining
whether a product was in a “defective condition unreasonably
dangerous”: the “consumer expectation test” and the “risk/benefit
analysis.” Id. at 581 ¶ 13 (quoting Dart, 147 Ariz. at 244). Relying on Dart,
the Golonka court then concluded that proving the product “failed to
perform as safely as an ordinary consumer would expect when used in an
intended or reasonable manner” or that the risks of a product’s design
outweigh its benefits establishes that a product is both defective and
unreasonably dangerous. Id. ¶ 14 (quoting Dart, 147 Ariz. at 245). By
declaring that satisfying either the consumer expectation test or the
risk/benefit analysis establishes both defective condition and unreasonable
danger, the Golonka court effectively eliminated the distinction between the
two elements. Thus, like Dillon, Golonka obviates the requirement that
defectiveness and unreasonable danger must be separately established in a
strict product liability claim.

¶16 The same analytical flaw appears in another Arizona case
involving defective design—a case the court of appeals also invoked here.
In Gomulka v. Yavapai Machine & Auto Parts, Inc., the court of appeals
addressed Arizona law governing defective design and stated that “[a]

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Opinion of the Court

defectively designed product is one that is made as the manufacturer
intended it to be but that is unreasonably dangerous.” 155 Ariz. 239, 241–42
(App. 1987). In reaching that conclusion, however, the Gomulka court
overlooked this Court’s jurisprudence that independently requires proof
that the product was defective.

¶17 By relying on Dillon, Golonka, and Gomulka, the court of
appeals here erred in vacating the superior court’s order granting Toyota’s
motion for summary judgment. To the extent that these cases collapse
defectiveness and unreasonable danger into a single concept, we
disapprove them. Moreover, we disapprove any language in Dart that
blurs the line between defective condition and unreasonable danger. The
longstanding distinction between defectiveness and unreasonable danger
is no mere syntactic accident. As stated above, the unreasonable danger
element prevents strict liability from transforming into absolute liability.
See supra ¶ 12. Similarly, the threshold requirement of defectiveness serves
to curtail liability when a product that is fit for its purpose causes an injury
simply because its normal use poses inherent risks. See Estabrook v. J. C.
Penney Co., 105 Ariz. 302, 307 (1970) (concluding jury instructions on strict
liability were not warranted because there was no evidence that the
escalator which injured the plaintiff was defective). Together, defectiveness
and unreasonable danger substantiate strict product liability. The two
concepts are neither optional nor are they one and the same.

II.

¶18 Because our cases have not always clearly distinguished these
concepts, we now delineate both the elements of a strict product liability
claim and the relationship among them. Accordingly, we reaffirm that a
plaintiff establishes a prima facie case of strict product liability by showing
that (1) the product was defective, (2) the defect rendered the product
unreasonably dangerous, and (3) the defect proximately caused the
plaintiff’s injuries. See Jimenez v. Sears, Roebuck & Co., 183 Ariz. 399, 402
(1995). We further take this opportunity to clarify the governing principles
by defining the terms “defective” or “defective condition” and
“unreasonably dangerous,” and by explaining the procedural framework
governing the relationship between those concepts.

¶19 As this Court recognized in Readenour, a “defect” is distinct
from an “unreasonable danger.” 149 Ariz. at 446–47. Readenour explained
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Opinion of the Court

that a product is “defective” or in a “defective condition” when it is “unsafe
for ‘normal handling and consumption.’” Id. at 447 (quoting Restatement
§ 402A cmt. h); see also Bailey v. Montgomery Ward & Co., 6 Ariz. App. 213,
218 (1967) (defining a “defective article” as a product “that is not reasonably
fit for the ordinary purposes for which such articles are sold and used”
(citation modified)).

¶20 By contrast, a product is “unreasonably dangerous” when it
is “more dangerous than a consumer would expect or whose risks outweigh
its benefits.” Readenour, 149 Ariz. at 447. In Readenour, this Court
reaffirmed that proof of defectiveness alone is insufficient to establish strict
product liability. Such liability arises only when the defective condition
also renders the product unreasonably dangerous. Preserving this
distinction provides parties and courts with a more defined analytical
framework for determining when a defective product gives rise to strict
product liability.

¶21 With these definitions in mind, we reaffirm the framework
governing whether a product is in a “defective condition unreasonably
dangerous.” Because defectiveness and unreasonable danger are
analytically distinct, a plaintiff must establish both. A plaintiff must first
prove that the product was defective. Absent such a showing, the inquiry
ends and the product liability claim fails. If the plaintiff establishes a defect,
however, the analysis does not end there. The plaintiff must also prove that
the defect rendered the product unreasonably dangerous. Only when both
elements are satisfied may strict product liability be imposed.

¶22 In Readenour this Court used the two tests identified in Dart
but confined them to determining whether a product is “unreasonably
dangerous”: the consumer expectation test and the risk/benefit analysis.
See 149 Ariz. at 447. Under the “consumer expectation test,” the factfinder
determines whether a product “failed to perform as safely as an ordinary
consumer would expect when used in an intended or reasonable manner.”
Dart, 147 Ariz. at 245 (quoting Barker v. Lull Eng’g Co., 573 P.2d 443, 446 (Cal.
1978)). By contrast, the “risk/benefit analysis” requires the factfinder to

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Opinion of the Court

consider several relevant factors 1 and determine whether “the benefits of
[a] challenged design . . . outweigh the risk of danger inherent in [the]
design.” Id. (quoting Barker, 573 P.2d at 446).

¶23 Dart also articulated the likely circumstance when each test
applies. See id. at 244–45. The Court explained that, in manufacturing
defect cases, the consumer expectation test functions effectively because
consumers develop safety expectations through experience with properly
manufactured products of the same general design. See id. at 244. The
Court cautioned, however, that this test may have more limited utility in
design defect cases because “the consumer would not know what to expect,
because he would have no idea how safe the product could be made.” Id.
(quoting John W. Wade, On the Nature of Strict Tort Liability for Products,
44 Miss. L. J. 825, 829 (1973)). Consequently, when the consumer
expectation test cannot feasibly be applied in a design defect case, courts
should instead employ the risk/benefit analysis to determine whether the
defect renders the product unreasonably dangerous. See id. at 244–46.

¶24 Applying these definitions and the framework for
determining whether a product is defective and unreasonably dangerous,
we conclude that the 4Runner was not defective.

1 This Court approved the following non-exhaustive list of factors to
determine whether a defect is unreasonably dangerous under the
risk/benefit analysis:
(1) The usefulness and desirability of the product,
(2) the availability of other and safer products to meet the
same need,
(3) the likelihood of injury and its probable seriousness,
(4) the obviousness of the danger,
(5) common knowledge and normal public expectation of the
danger (particularly for established products),
(6) the avoidability of injury by care in use of the product
(including the effect of instructions or warnings), and
(7) the ability to eliminate the danger without seriously
impairing the usefulness of the product or making it unduly
expensive.
Dart, 147 Ariz. at 245–46 (quoting Byrns, 113 Ariz. at 267).

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Opinion of the Court

A. A lack of LDW did not place the 4Runner in a
defective condition.

¶25 As previously noted, a product is defective if it is “unsafe for
‘normal handling and consumption.’” Readenour, 149 Ariz. at 447 (quoting
Restatement § 402A cmt. h); see also Restatement § 402A cmt. g (defining
“[d]efective condition” as “a condition not contemplated by the ultimate
consumer, which will be unreasonably dangerous to him”). A defect,
therefore, is a condition or characteristic of the product not reasonably
contemplated by the ordinary consumer that renders the product unsafe for
its intended use.

¶26 Here, we conclude that consumers reasonably expect that
vehicles are designed to allow them to drive within marked lanes, and we
agree with Toyota that the Maywalds failed to establish that the 4Runner
did not deliver on that expectation. There is an expectation that safety
devices will guard against injury by accidents. But there is no expectation
that a vehicle will prevent human error in careless driving. Although LDW
technology may enhance vehicle safety, it does not eliminate the driver’s
fundamental responsibility to maintain control of the vehicle. Nor can it
reasonably be disputed that an ordinary driver understands the obligation
to stay awake and remain within the proper lane of travel, and appreciates
the inherent danger of crossing into a lane occupied by oncoming traffic.
See A.R.S. § 28-729(1) (“[A] person shall drive a vehicle as nearly as
practicable entirely within a single lane and shall not move the vehicle from
that lane until the driver has first ascertained that the movement can be
made with safety.”).

¶27 The Maywalds alleged a single defect: the 4Runner lacked an
LDW system. 2 But the absence of that feature did not render the vehicle
unsafe for its intended and ordinary use. The normal operation of a vehicle
requires an attentive driver to steer and maintain control, and a driver

2 The Maywalds alleged that the 4Runner lacked any of the various
available lane departure prevention technologies, including lane departure
warning, lane keeping assist, and lane centering assist. Because the
technologies all serve the same purpose—helping a driver maintain the
proper lane of travel—we conclude that the lack of any of these systems is
the same purported defect.
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asleep at the wheel is not engaging in normal use. Because the absence of
LDW technology did not render the 2019 4Runner unsafe for ordinary use,
the vehicle was not defective. See Rogers, 115 Ariz. at 307 (“That the Unimac
Company could have adopted a different type of safety device, [i.e.] a lid
lock, is not in itself sufficient evidence to establish defective design.”);
Brown v. Sears, Roebuck & Co., 136 Ariz. 556, 563 (App. 1983) (“The fact that
an alternate safety feature may be available does not in and of itself render
a product . . . defective and unreasonably dangerous.”).

¶28 We find persuasive the analysis of the New Jersey Appellate
Division, which held that the absence of an available driver-assistance
system does not render an otherwise safe vehicle defectively designed. See
Berkoski v. Honda Motor Co., 328 A.3d 986 (N.J. Super. Ct. App. Div. 2025).
In Berkoski, as here, the plaintiff asserted that a vehicle was defectively
designed because it was not equipped with an available LDW system. Id.
at 987. The court rejected that claim, concluding that the plaintiff failed to
demonstrate that the absence of the LDW system rendered the vehicle
unsafe. Id. at 993–94. In reaching that conclusion, the court explained that
although an LDW system may aid a driver it does not displace the obvious
expectation that the driver remains responsible for steering and controlling
the vehicle. Id. at 993. We find Berkoski’s rationale equally applicable and
dispositive here.

¶29 Rather than Berkoski, the Maywalds urge us to follow Ortiz v.
Daimler Truck North America LLC, 112 Cal. App. 5th 608 (2025). Ortiz
addressed a different issue than the one presented here. Ortiz considered
whether a manufacturer’s alleged failure to install collision-avoidance
technology could be resolved on summary judgment based on duty and
proximate-cause principles. Id. at 613–14. The court declined to address
whether the truck was defectively designed. Id. at 636–37. Accordingly,
Ortiz never confronted the threshold issue presented here—whether the
absence of driver-assistance technology rendered the product defective in
the first instance. Ortiz does not inform or affect our conclusion that a lack
of LDW does not render the 4Runner defective.

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B. Because the 4Runner was not sold in a defective
condition, the Maywalds’ negligent design and loss
of consortium claims cannot proceed.

1. The Maywalds have not made the
threshold showing of defect required in a negligent
design claim.

¶30 Because they cannot establish that a lack of LDW is a defect,
the Maywalds’ negligent design claim also fails. Negligent design defect
claims and strict liability design defect claims are distinct theories of
liability. The former theory “concerns itself with determining whether the
conduct of the defendant was reasonable in view of the foreseeable risk of
injury.” Dart, 147 Ariz. at 246. And the latter theory “is concerned with
whether the product itself was unreasonably dangerous.” Id. Nevertheless,
a negligent design defect claim, like a strict liability design defect claim,
requires establishing that the product at issue was defective in the first
instance. See Mather v. Caterpillar Tractor Corp., 23 Ariz. App. 409, 411 (1975)
(“Under the negligence theory a ‘design defect’ arises when the
manufacturer has failed to use reasonable care to design its products so as
to make it safe for intended uses.”). Thus, failure to establish a defect
proves fatal to both of the Maywalds’ theories of liability.

2. The Maywalds do not have a viable
underlying tort claim to sustain their loss of
consortium claim.

¶31 Lastly, without a viable underlying tort claim, the Maywalds’
loss of consortium claim is also untenable. See Barnes v. Outlaw, 192 Ariz.
283, 286 ¶ 8 (1998) (noting that “loss of consortium is a derivative claim”
and thus its existence depends upon successfully proving the elements of
an underlying claim).

C. The risk/benefit analysis is only concerned with the
risks and benefits of the challenged design.

¶32 Given that the Maywalds failed to make a threshold showing
of defectiveness, we need not determine whether the 4Runner was
unreasonably dangerous. See supra ¶ 21. Nonetheless, we deem it prudent
to clear up confusion concerning the proper focus of the risk/benefit

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analysis. In this case, the court of appeals applied the risk/benefit analysis
and concluded that summary judgment was improper because genuine
issues of material fact existed regarding whether the benefits of
incorporating LDW technology into the 4Runner’s design outweighed the
risks associated with omitting it. See Maywald, 2024 WL 5165445, at *7 ¶ 21.
The court, however, erred in applying that analysis.

¶33 The risk/benefit analysis asks whether, when considering
certain relevant factors, “the benefits of the challenged design . . . outweigh
the risk of danger inherent in [the] design.” Dart, 147 Ariz. at 245 (emphasis
added) (quoting Barker, 573 P.2d at 446). Under our jurisprudence, that
inquiry focuses on the risks and benefits inherent in the challenged design
itself—here, the 4Runner without LDW technology. The court of appeals
departed from that framework by comparing the challenged design to an
alternative design incorporating LDW technology. To be sure, two factors
in the risk/benefit analysis concern alternative designs—“the availability
of other and safer products to meet the same need” and “the ability to
eliminate the danger without seriously impairing the usefulness of the
product or making it unduly expensive.” Dart, 147 Ariz. at 245–46 (quoting
Bryns, 113 Ariz. at 267). But strict liability does not arise from weighing the
risks and benefits of an alternative design, as the court effectively
concluded here. Were it otherwise, manufacturers would essentially be
required to incorporate every feasible safety feature or face potential
liability, a result that could render many products prohibitively expensive.
Our inquiry therefore remains focused on whether the product, as designed
and sold, was reasonably safe for its intended and ordinary use, not
whether additional features could have made it safer.

¶34 A proper application of the risk/benefit analysis does not ask
whether Toyota could have designed a safer 4Runner by adding LDW
technology. Rather, it asks whether the risks inherent in the challenged
design—the 4Runner as sold without LDW technology—outweighed its
benefits. Evidence concerning the feasibility or utility of an alternative
design may inform that inquiry, but it cannot supplant it. Because the court
of appeals framed the analysis around the comparative merits of a design
incorporating LDW technology, rather than the risks and benefits of the
challenged design itself, it misapplied the risk/benefit analysis.

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CONCLUSION

¶35 We reaffirm that Arizona’s strict product liability doctrine
requires proof that a product is both defective and unreasonably
dangerous. Preserving those distinct inquiries ensures that strict liability
remains confined to defective products and does not become a form of
absolute liability. For the foregoing reasons, we vacate the court of appeals’
decision and affirm the trial court’s summary judgment in favor of Toyota.

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